This thread will provide news and information on the ongoing dispute with HMRC over the Montpelier double tax scheme (BN66/s58). It may also be of interest to deGraaf and Steed users.
I will try and post an update every Friday morning, whether there is anything to report or not.
The latest status of the Montpelier Huitson appeal will be updated below.
Huitson -v- HMRC
Last year (2015) Montpelier's appeal was heard at the First-tier Tax Tribunal (FTT). They lost (link to summary of FTT decision) but said they intended to appeal to the Upper Tax Tribunal (UTT).
8th August 2016 - Unfortunately, Montpelier's appeal to the UTT was submitted late. As a result, it is now being referred to a Judge to decide whether permission should be granted for a late appeal. If this Judge refuses permission then Montpelier can appeal his/her decision. The timescales for this are unknown.
4th October 2016 - The Judge refused permission for the late appeal. Montpelier are now appealing this decision, and there will be a hearing within the next 2 months. From what I hear, it is very unlikely they will succeed. Only in exceptional circumstances, like serious illness, are late appeals allowed.
18th October 2016 - Update from the UTT - "There has been no final decision on this late appeal. We are still in the process of fixing a hearing."
30th October 2016 - HMRC have started issuing actual Follower Notices and APNs to people who've received the warning letter.