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HMRC enquiries for Schemes through ASMG / White Collar

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    Originally posted by dangerouswhensober View Post
    A WC representative told me (most categorically) that the WC scheme was NOT DOTAS-listed - but the ASMG scheme WAS ...

    Which suggests that (1) no-one should receive an APN for years in which they were members of the WC scheme only, and (2) anyone receiving an APN for years in which they were members of both schemes (as I was) would have a valid grounds for objection (to the figures in that APN) ...
    DOTAS seems to be the automatic way to issue an APN. However it certainly doesnt seem limited to DOTAS.
    https://www.gov.uk/government/upload...DOTAS_GAAR.pdf

    Legislation will be introduced in Finance Bill 2014 to enable HMRC to issue a ‘Notice to Pay’
    to any taxpayer for whom there is an open enquiry, or the matter is under appeal, and who
    has claimed a tax advantage by the use of arrangements that:
    • fall to be disclosed under DOTAS, or
    • HMRC counteracts under the GAAR following an opinion of the GAAR Advisory Panel
    that, in the Panel’s opinion, the arrangements are not a reasonable course of action.


    I guess it all depends on what the GAAR Advisory Panel decides for relevant schemes.

    Comment


      Originally posted by holymoly23m View Post
      DOTAS seems to be the automatic way to issue an APN. However it certainly doesnt seem limited to DOTAS.
      https://www.gov.uk/government/upload...DOTAS_GAAR.pdf

      Legislation will be introduced in Finance Bill 2014 to enable HMRC to issue a ‘Notice to Pay’
      to any taxpayer for whom there is an open enquiry, or the matter is under appeal, and who
      has claimed a tax advantage by the use of arrangements that:
      • fall to be disclosed under DOTAS, or
      • HMRC counteracts under the GAAR following an opinion of the GAAR Advisory Panel
      that, in the Panel’s opinion, the arrangements are not a reasonable course of action.


      I guess it all depends on what the GAAR Advisory Panel decides for relevant schemes.
      Agreed on the above.

      HMRC originally said that they would issue 43,000 APN's. That was increased to 64,000 at the last budget.
      The plan was for a 20 month issue period beginning last August.
      I have no idea how many have been issued so far, but I'm guessing it's less than 10,000.
      The original 20 month period will be extend by at least 6 months for the 21,000 new APN's announced.
      Only then might attention turn to non notified but notifiable schemes - info is incredibly difficult to get.
      GAAR is nowhere near a first case.
      A Follower Notice is probably more likely but perhaps a year away minimum.
      Best Forum Adviser & Forum Personality of the Year 2018.

      (No, me neither).

      Comment


        Originally posted by webberg View Post

        I have no idea how many have been issued so far, but I'm guessing it's less than 10,000.
        Page 12, section 2.25:

        "... As at 13 March 2015, HMRC has already issued (APN) 7,712 notices with a value of £1.6 billion."

        https://www.gov.uk/government/upload...right_sig_.pdf
        "If You Tolerate This Your Children Will Be Next ..."

        Comment


          Originally posted by dangerouswhensober View Post
          Page 12, section 2.25:

          "... As at 13 March 2015, HMRC has already issued (APN) 7,712 notices with a value of £1.6 billion."

          https://www.gov.uk/government/upload...right_sig_.pdf
          Thanks - so less than 10,000 is probably correct.

          We need a Parliamentary question about how many have been issued, how many of those have had representations made against them, how many withdrawn, how many stayed due to a JR, how many paid.
          Best Forum Adviser & Forum Personality of the Year 2018.

          (No, me neither).

          Comment


            Originally posted by webberg View Post
            Thanks - so less than 10,000 is probably correct.

            We need a Parliamentary question about how many have been issued, how many of those have had representations made against them, how many withdrawn, how many stayed due to a JR, how many paid.
            And I've just done that.
            Best Forum Adviser & Forum Personality of the Year 2018.

            (No, me neither).

            Comment


              PM Permission

              Could you set me up with PM rights as well please?

              Many Thanks

              Comment


                WC have explained to me their plans for support going forwards - and what it will cost me.

                Wondered what others were doing?

                PM me if you like.

                Comment


                  PM rights

                  Could you set me up with PM rights as well please?

                  Comment


                    Originally posted by mags8 View Post
                    Could you set me up with PM rights as well please?
                    Done!

                    Comment


                      I have kept in touch with WC all the way thru and they have now come up with a plan. However I am more than a bit sceptical especially as the firm they are suggesting we sign up with, appear to be a one-man band private ltd co. It is also going to cost quite a bit up-front.
                      Presumably others on this forum have also received this offer from WC. I'd be interested to know what others intend to do re WC's offering.

                      Admins could I have PM rights please?

                      Comment

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