Disguised remuneration: transfer of liability — technical note
This technical document sets out how HM Revenue and Customs will collect outstanding tax liabilities from the appropriate person where it can't reasonably collect the liability from the employer.
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This guide will be fully updated at the start of 2024.
Find out the latest guidance about settling disguised remuneration scheme use and paying the loan charge in HMRC issue briefing: settling disguised remuneration scheme use and/or paying the loan charge.
The technical note describes how HM Revenue and Customs (HMRC) will transfer the tax liability from the employer to the employee, when HMRC can’t reasonably collect the liability from the employer. It details the process for the transfer in three separate scenarios; where the employer no longer exists, is offshore, or can’t pay the liability. The note also contains the primary and secondary legislation that will be introduced to allow HMRC to transfer the liability from employer to employee.
Last updated 6 December 2023 + show all updates
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Information on where to find the latest guidance on settling disguised remuneration scheme use and paying the loan charge has been added.
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The email contact details for contractor loan schemes and all other disguised remuneration schemes has been updated.
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First published.