Green Light Tax Resolutions

17/07/2026

Loan Charge Settlements - Statutory Instrument 2026 No.821

The Employment and Trading Income etc. (Loan Charge Settlement Scheme) Regulations 2026 were laid before the House of Commons on 15 July 2026 and come into force as of 5 August 2026.

Now that the secondary part of this legislation has been passed, HMRC will begin to put it into practice and start contacting taxpayers who have registered an interest in settling under the new terms. Those that haven't, may have a significantly longer wait.

If you have registered an interest in settling under the new terms, you could be receiving an update or an offer letter very shortly......

As ever we are here to support Tax Advisors, Accountants and Taxpayers as they work through this process and endeavour to reach a settlement with HMRC for themselves or their clients.

Jamie Green
07943 123396
[email protected]

A link to the new legislation is below, for anyone who fancies a bit of light reading!😂

https://www.legislation.gov.uk/uksi/2026/821/introduction/made

These Regulations establish the Loan Charge Settlement Scheme following the government’s response, published at Budget 2025, to the Independent Loan Charge Review of Mr. Ray McCann. They set out when and how settlement offers may be made and settlement agreements reached with those who are liable ...

17/04/2026

Could the new Loan Charge Legislation cost you money?

Do you currently have a contract with HMRC and are paying off a settlement that will be recalculated under the new terms as part of the Loan Charge Review?

If so, it’s possible you may be affected by part of the legislation, which means that once your new liability is calculated, you have overpaid. According to HMRC these amounts will not be repaid to the taxpayer, and the debt will just be treated as cleared.

If you are in this position, it may be beneficial to stop making payments to HMRC so that you don’t end up with an overpayment you cannot get back. This could for example happen in cases where under a Time To Pay arrangement, you have now paid off the tax liability and have interest left – which may very well be reduced to nil, under the new legislation, depending on the size of the debt.

According to HMRC guidance published in February 2026, taxpayers who agreed a contract settlement, including loan charge liabilities after 1 June 2021, will be eligible for the new settlement opportunity if those amounts have not been paid in full.

https://www.gov.uk/government/publications/hmrc-issue-briefing-operational-activity-following-the-new-independent-review-of-the-loan-charge/hmrc-loan-charge-review-technical-note -for-the-loan-charge-settlement-scheme--finance-bill-2025-to-2026

The legislation in the Finance Bill provides that amounts paid by a customer against their original loan charge liability will be credited against the new settlement amount, but that this cannot create a repayment to the customer where the amount paid is greater than the new settlement amount.

HMRC have announced that further details will be provided in secondary legislation on how this is going to work and this could be by the end of May.

If you would like to discuss your case and need assistance in clarifying how or if this will affect you, please contact us and we will be happy to offer advice and help you through the new settlement process.

[email protected]
07943123396

We’d like to set additional cookies to understand how you use GOV.UK, remember your settings and improve government services.

03/04/2026

Getting advice from a Tax Dispute Specialist is an Eggsellent idea!

We wish everyone a Happy Easter and will be here to help and offer a free consultation and no obligation quote, when you are sick of chocolate!

[email protected]
07943123396