Q. I am affected by the loan charge & recently came across the fact that any information pertaining to contract loans had to be submitted by Sept 2018. I have since contacted the HMRC and I am will be providing them with details of my contractor loans. However my concern is that the response I received does not guarantee that the HMRC will not consider my situation before 5th April 2019 & therefore I cannot benefit from the settlement agreement. Can you please advise.
A. As you rightly point out users of disguised remuneration schemes should have registered their interest and all the information required to settle must have been sent to HMRC by 30 September 2018.
It is assumed you will be registering and providing the information shortly.
Whilst the deadline date has been passed an it is unlikely you will have and agreed settlement by 5th April 2019 it is recommended that you at least register and provide all the information before 5 April 2019.
Whilst you may still be caught by the charge the fact you have registered may give you some mitigation on settlement.
You should also ensure the scheme is no longer in operation.
The following link may assist – HMRC issue briefing: disguised remuneration charge on loans