I have a client who had received loans from umbrella companies for a few years up to 2017. It seems unlikely that the loans will ever be repaid and so far, no interest has been paid although it has apparently been accrued. I originally thought that all such loans that had not been repaid or in respect of which settlement had not been reached with HMRC would have to be disclosed on the 2019 tax return (and notified to HMRC by 30 September 2019). However, one umbrella company has stated that we should not disclose the loans that it (or its predecessor companies) had made as they were made direct from the umbrella company with whom the employee had an employment contract rather than via a third party. Articles I have read on this subject suggest that all loans are likely to be caught unless specifically exempt (e.g. certain commercial loans). My reading of S.554A ITEPA does indeed seem to require there to be third party involvement for the loan charge to apply, so can I advise the client to accept the umbrella company's advice or can readers point me in the right direction for further research?