Guidance

Disguised remuneration: transfer of liability — technical note

This technical document sets out how HMRC will collect outstanding tax liabilities from the appropriate person where it cannot reasonably collect the liability from the employer.

From:
HM Revenue & Customs
Published
1 December 2017
Last updated
20 December 2023 — See all updates

Documents

Tackling disguised remuneration

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Annex A

PDF, 207 KB, 2 pages

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Annex B

PDF, 338 KB, 4 pages

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Details

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 HMRC will transfer the tax liability from the employer to the employee, when HMRC cannot reasonably collect the liability from the employer. It details the process for the transfer in 3 separate scenarios — where the employer no longer exists, is offshore, or cannot 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.

Updates to this page

Published 1 December 2017
Last updated 20 December 2023 + show all updates

  1. Contact details for contractor loan schemes and all other disguised remuneration schemes have been updated.

  2. Information on where to find the latest guidance on settling disguised remuneration scheme use and paying the loan charge has been added.

  3. The email contact details for contractor loan schemes and all other disguised remuneration schemes has been updated.

  4. First published.

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