Late elections to spread outstanding disguised remuneration loan balances over three tax years will be accepted up to 31 December 2020, says HMRC in statement of practice 1/2020. This extends the deadline from 30 September 2020.
HMRC states that it will consider elections submitted after 31 December but will accept them only in exceptional circumstances beyond the individual’s control - mostly relating to illness of the taxpayer. It would consider that oversight or negligence on the part of the taxpayer or their agent, or illness or absence of the adviser as unlikely to qualify.