Tax Avoidance:Written question - 152724 - enquiry time limits and the 2019 Loan Charge

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Dear HM Revenue and Customs,

With reference to "Tax Avoidance:Written question - 152724" found here

Stride's answer says "HMRC will only go to the employee to settle their income tax liability in cases where it cannot reasonably be collected from the employer, for example where the employer is no longer in existence."

He also says "However, these schemes never worked and the amounts paid were always taxable under the law at the time."

For individuals and employers who were involved in arrangements expected to be subjected to the 2019 Loan Charge

1) Please tell me how many individuals will be taxed under the 2019 Loan Charge where their employer is no longer in existence.

2) Please tell me how many employers went out of existence while under tax avoidance enquiries by HMRC.

3) Please tell me how many employers that are no longer in existence but should have paid income tax liability under the law at the time they were in existence will have that income tax liability transferred to individuals via the 2019 Loan Charge.

Where HMRC failed to open an enquiry on a taxpayer or employer/scheme:

4) Can please give me the number of individuals that will have income tax liability transferred to them (from the employer) under the 2019 Loan Charge that could not be transferred to them on 5/4/19 (using the law at the time the amounts were paid) as standard enquiry time limits will no longer be available for HMRC to open an enquiry.

Yours faithfully,

Chris Sawyer on behalf of FOI Central Team, HM Revenue and Customs

Our ref: FOI2018/01307

Dear Mr Sawyer,

Freedom of Information Act 2000 Acknowledgement

Thank you for your communication of 22nd June which has been passed to
HMRC's Freedom of Information Team.

We have allocated the above reference which you should quote if you need
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Yours sincerely

HMRC Freedom of Information Act Team