The information you have requested is not available. HMRC are working through the settlement process with those Disguised Remuneration users who came forward to settle their tax affairs before 5 April 2019.
Scheme users who chose not to repay the outstanding loan, or agree a settlement with HMRC, by 5 April 2019, are now liable for the loan charge and should report it as part of their 2018-19 tax liability.
To date, no promoters of disguised remuneration (DR) schemes have been convicted of criminal offences related to DR schemes as such. There are no criminal offences specific to the promotion of mass marketed tax avoidance schemes but HMRC may conduct a criminal investigation into an individual’s actions when, for example, reliance is placed on a false or altered document, or if the material facts are misrepresented. In May, six individuals were arrested on suspicion of promoting fraudulent loan charge arrangements.
Since the formation of HMRC’s Fraud Investigation Service on 1 April 2016, more than 20 individuals have been convicted for offences relating to arrangements which have been promoted and marketed as tax avoidance schemes, resulting in over 100 years in custodial sentences. A significant number of avoidance scheme promoters are currently under criminal investigation by HMRC.