On 14 February 2019, HMRC published Spotlight 48 and updated its policy paper on disguised remuneration and the loan charge.

Spotlight 48 states that some advisers have mistakenly advised taxpayers who have taken out disguised remuneration loans that the lender needs to execute a deed of release or exclusion of the loan before HMRC will agree a settlement.

The Spotlight confirms that HMRC does not require such a deed to be executed.

The updated policy paper sets out the background to the 5 April 2019 loan charge, the courses of action open to taxpayers and HMRC's settlement opportunity.

A copy of Spotlight 48 can be viewed here.

A copy of the policy paper can be viewed here.