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HMRC reminds employers to report loans on forms P11D

Author: ICAEW Insights

Published: 27 May 2025

HMRC has asked companies whose financial statements show loans to directors and employees of more than £10,000 each to check if they need to include the loans on forms P11D for 2024/25.

Form P11D process 

Employers must report taxable expenses or benefits provided to an employee to HMRC. This can be done through the payroll for some benefits where the employer has registered before the start of the tax year. Most employers report taxable benefits and expenses by completing an end-of-year form P11D for the employee.  

The deadline for submitting form P11D for 2024/25 is 6 July 2025. The company must also report any Class 1A national insurance contributions due by the same date, using form P11D(b).   

Loans 

The rules relating to loans can be complicated to apply. Briefly, a loan provided to an employee or director, or to the relative of an employee/director, may give rise to a taxable benefit where: 

  • no interest is charged or, if interest is charged, the rate is less than the official rate of interest (2.25% for 2024/25); and
  • the amount of the loan exceeds £10,000 at any point during the tax year. 

Exceptions apply in some limited circumstances. 

It should be noted that a taxable benefit will arise to the employee/director even if the loan is repaid within nine months of the end of the accounting period, which is when a tax charge applies to the company on an outstanding loan. This can cause confusion.  

Currently, taxable benefits relating to loans cannot be payrolled and must be reported on form P11D.  

Action taken by HMRC 

HMRC has written to employers with guidance on how to determine if a loan gives rise to a taxable benefit. In the letter, HMRC reminds the employer that they must report any taxable benefits for 2024/25 by submitting forms P11D and P11D(b) by 6 July 2025.  

HMRC explains that the letter is not a compliance check and that HMRC has written to the employer to help it avoid making mistakes in the future. 

 

Further information 

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