What was it about a loan scheme that was so egregious that it merited an unprecedented and, arguably, cruel remedy? The question is more intriguing given the generous settlement opportunities HMRC have used to incentivise taxpayers who had evaded and avoided tax.

It is not easy to reconcile the HMRC treatment of contractors caught by the loan charge with those individuals who had fraudulently evaded tax using secretive offshore jurisdictions, or very large businesses putting eye-watering amounts of corporation tax, PAYE and NIC at avoidance risk through structured tax planning and employee benefit trusts (EBTs).