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Forum: HMRC Scheme Enquiries

For discussions relating to enquiry letters being sent out by HMRC.

  1. Sticky Thread Sticky: BIG GROUP

    Mod edit: Joining instructions. This started elsewhere but should be on its own. I have two takers so far. To clarify this BIG GROUP is ONE GROUP across ALL schemes. It does not impact action individuals may wish to take on their own or via other groups.

    Started by webberg, 24th April 2015 14:32
    90 Pages
    1 2 3 ... 90
    • Replies: 897
    • Views: 188,001
    23rd June 2017 15:05 Go to last post
  2. Sticky Thread Sticky: Montpelier DTA scheme bulletin

    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...

    Started by DonkeyRhubarb, 8th August 2016 18:38
    35 Pages
    1 2 3 ... 35
    • Replies: 344
    • Views: 89,498
    23rd June 2017 09:04 Go to last post
  3. Sticky Thread Sticky: Discovery assessment season - unexpected bills from HMRC

    The threads are filling up with stories of unexpected bills arriving from HMRC. Whilst there is no substitute for getting proper advice that suits your own circumstances, the following general description may help reduce the shock. However if you have an accountant - ask her/him for help. If...

    Started by webberg, 9th March 2017 10:05
    5 Pages
    1 2 3 ... 5
    • Replies: 46
    • Views: 8,941
    22nd June 2017 12:42 Go to last post
  4. Sticky Thread Sticky: HMRC Enquiry letters on Loans from EBT and other schemes

    If you have generic questions regarding HMRC enquiries, this is the thread for you. If you have questions about your own enquiry or want to make contact with others who have used your loan scheme provider, look for the thread in this sub-forum. The first thing to point out, however: WE ARE NOT...

    Started by cojak, 11th February 2013 10:30
    134 Pages
    1 2 3 ... 134
    • Replies: 1,331
    • Views: 479,530
    26th May 2017 14:48 Go to last post
  5. Sticky Thread Sticky: Disappearing loans?

    It's a common feature of these threads that lenders have become difficult to find and engage with. We have recently had some experience in this arena. In most schemes that used loans, certainly until 2011, loans were advanced by the company acting as trustee for a trust. In some cases, the...

    Started by webberg, 13th April 2017 17:12
    • Replies: 2
    • Views: 1,715
    17th May 2017 11:33 Go to last post
  6. Sticky Thread Sticky: What an APN looks like

    I now have such a beast and am trying to find a way to get it on a forum thread. It's a scanned document on my desktop that doesn't seem to want to attach itself to a message like this. Help?

    Started by Rob79, 25th September 2014 16:27
    10 Pages
    1 2 3 ... 10
    • Replies: 96
    • Views: 36,803
    10th February 2017 14:27 Go to last post
  7. Sticky Thread Sticky: Tempted to join a new contractor scheme? Ask the following

    13 Questions you MUST ask about any scheme you are offered The following is based on a piece originally written by and now replicated with kind permission of Jolyon Maugham QC and first appeared on the waitingfortax blog in 2014. I have shortened it and consequently any errors are mine. ...

    Started by webberg, 12th June 2015 15:08
    • Replies: 7
    • Views: 8,949
    23rd March 2016 14:41 Go to last post
  1. "PSC Structure" with Aston Mae - is this above board?

    Hi, I'm a web developer in London with a LTD company. I was looking for ways to reduce my tax and was recommended Aston Mae. I would like to know your opinion on whether it's above board. Below is part of the email they sent me: ----- <email content removed>

    Started by baj84, 12th November 2014 08:06
    2 Pages
    1 2
    aston mae, psc, scheme
    • Replies: 17
    • Views: 4,062
    13th November 2014 08:27 Go to last post
  2. Tax case on jurisdiction of s 739 - ToAA - Fisher

    A decision on the above case (TC03921) was released in August this year following a hearing in February 2013. The key question was whether the UK's rules on taxation of assets transferred abroad could be defeated by 1. a need for INCOME TAX to be avoided 2. a need to be applied to...

    Started by Rob79, 7th November 2014 14:14
    2 Pages
    1 2
    • Replies: 15
    • Views: 3,166
    11th November 2014 11:08 Go to last post
  3. Is using an agency subject to DOTAS registration?

    You would have thought not. However I hear the faintest whisper of a rumour that we may soon see some form of press release from our friends at HMRC suggesting that as part of their policing of the DOTAS regime, certain agency arrangements that create a tax advantage "should be" DOTAS...

    Started by Rob79, 6th November 2014 13:27
    3 Pages
    1 2 3
    • Replies: 26
    • Views: 2,819
    10th November 2014 16:43 Go to last post
  4. ToAA

    For ToAA to apply, Tax avoidance should be a motive. EBT has been proven legal before and Ranger's, Deutsche, UBS all have won. So if tax benefit to contractor is because of EBT Loans and NOT by Transferring asset abroad, how can tax avoidance be a motive and thus how should ToAA apply?...

    Started by StrengthInNumbers, 3rd November 2014 14:46
    • Replies: 3
    • Views: 1,348
    3rd November 2014 18:24 Go to last post
  5. Judicial Review - HMG attempt to stifle - defeated

    http://www.publications.parliament.uk/pa/ld201415/ldhansrd/lhan46.pdf The above (113 pages) is yesterday in the House of Lords. Read pages 952 thru 982. In short HMG tried to change the terms and conditions under which a judicial review challenge could be brought. Although the debate is...

    Started by Rob79, 28th October 2014 10:17
    • Replies: 3
    • Views: 1,861
    29th October 2014 14:13 Go to last post
  6. Another Consulting Overseas Victim?

    I contracted through this lot between 2003-4 and since then have been out of the UK. Just received a Notice of Further assessment from HMRC "Special Civil Investigations" department for approx 20K for the year to April 2004 Interest is also payable (although not detailed) from Jan 05 and a...

    Started by Bert, 14th February 2008 12:30
    17 Pages
    1 2 3 ... 17
    • Replies: 163
    • Views: 74,091
    22nd October 2014 19:22 Go to last post
  7. Groups - forming, storming, norming, reforming

    The above is the commonly held behavior pattern of groups. I've been asked by a few people recently what I think about groups coming together on various schemes. The following represents my thoughts and experience and will not necessarily accord with the actions of those groups I know already exist...

    Started by Rob79, 9th October 2014 09:52
    2 Pages
    1 2
    • Replies: 13
    • Views: 2,588
    20th October 2014 10:44 Go to last post
  8. Contractor loans settlement offer - what are people doing?

    I've been caught up on this contractor loans affair as I worked for a company in the Isle of Man that actually provided this service. A stipulation of the contract was that I had to use their payment system. It's not as if I used them to avoid tax but obviously I regret it now :D. I just wanted...

    Started by CUK1357819, 12th October 2014 20:01
    contractor loan, hmrc, settlement offer
    • Replies: 2
    • Views: 2,031
    13th October 2014 12:33 Go to last post
  9. Section 28A Notice of Closure of Enquiry

    On the 2nd of March 2009 I received a Section 28A Notice of Closure of Enquiry for the tax period 2005 - 2006. At the weekend I received a reply from HMRC stating my position on this EBT mess. This included details of them having opened a Section 9a enquiry into the tax years ending 5...

    Started by DownButNotOut, 13th October 2014 08:46
    • Replies: 1
    • Views: 1,271
    13th October 2014 10:26 Go to last post
  10. Agents receiving confirmations of schemes

    I remember some of the agents I worked through would not deal with offshore companies and any of the currency or lain schemes. Some did after they had clarification of the scheme. Now I am not sure if that would have come from the scheme provider, their tax counsel or you know who themselves. My...

    Started by Fred Flinstone, 10th October 2014 16:01
    • Replies: 0
    • Views: 672
    10th October 2014 16:01 Go to last post
  11. Discovery Assessments and COP 8

    Hi Can anyone clarify if a Discovery Assessment is an enquiry opened under a COP 8? I'm trying to understand if those with a DA are in the firing line for an APN. Thank you in advance.

    Started by linuxcat, 20th September 2014 06:08
    2 Pages
    1 2
    • Replies: 10
    • Views: 2,539
    8th October 2014 08:20 Go to last post
  12. HMRC Consultative Document - marketed tax avoidance schemes

    This is probably required reading if you have an open tax enquiry under Section 9A TMA 1970: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/275070/Tackling_marketed_tax_avoidance.pdf <admin note>Just fixed the pdf link - the HTML version can be viewed two posts...

    Started by Michael J Perry FCA, 28th January 2014 21:48
    41 Pages
    1 2 3 ... 41
    • Replies: 408
    • Views: 99,066
    2nd October 2014 20:32 Go to last post
  13. hector ackowldeges they said schema outside dotas but that doesn't mean tax not due

    My first post here so bear with me. I got a letter today from hmrc saying that although they had already reviewed my scheme and agreed it was outside dotas they have not agreed that arrangements are not taxbale I think this is a good thing because they would find it difficult to charge...

    Started by freddiedotas, 29th September 2014 17:04
    2 Pages
    1 2
    • Replies: 18
    • Views: 2,729
    2nd October 2014 19:24 Go to last post
  14. HMRC debt recovery

    http://www.legislation.gov.uk/uksi/2014/2438/pdfs/uksi_20142438_en.pdf There is a lot of debate on various threads regarding bankruptcy, Voluntary Arrangements, etc. I think it might be a good idea to consolidate thoughts here. As an opener please see the above. This allows HMRC to...

    Started by Rob79, 30th September 2014 12:54
    2 Pages
    1 2
    • Replies: 14
    • Views: 2,818
    1st October 2014 11:58 Go to last post
  15. HMRC recovery powers after APN

    I have been pondering the likely course of future events next year after I receive the expected APN in relation to past "Discovery" assessments by HMRC. (In my case, these assessments total ~ 50,000 for EBT scheme membership over three years to April 2011). If/when I receive an APN, I will...

    Started by dangerouswhensober, 27th September 2014 09:35
    • Replies: 2
    • Views: 1,333
    27th September 2014 12:07 Go to last post
  16. Accelerated Payment Factsheet

    I presume HMRC may send this out prior to issuing APNs. http://www.hmrc.gov.uk/compliance/cc-fs24.pdf

    Started by DonkeyRhubarb, 17th September 2014 13:09
    • Replies: 8
    • Views: 1,706
    18th September 2014 19:40 Go to last post
  17. Exclamation APNs Imminent - your help needed

    No doubt some of you have already heard, HMRC are planning to send out all 43,000 APNs within 18 months: 'Thousands' of pay-up tax notices to hit doormats - 12 Sep 2014 - Accountancy Age NTRT would really like to see the format of an APN as soon as anyone receives one Once we get sight of...

    Started by SantaClaus, 14th September 2014 18:56
    3 Pages
    1 2 3
    • Replies: 25
    • Views: 5,225
    17th September 2014 15:21 Go to last post
  18. Recommended reading

    http://www.amazon.co.uk/HMRC-Majestys-Coaster-survive-investigation-ebook/dp/B00KC0H16Y/ref=sr_1_1?ie=UTF8&qid=1410951215&sr=8-1&keywords=hmrc+her+majesty%27s+roller+coaster (And no, I didn't write it and get no share of royalties).

    Started by Rob79, 17th September 2014 10:56
    • Replies: 0
    • Views: 681
    17th September 2014 10:56 Go to last post
  19. Settlement groups - common purpose?

    This section of the website has details of perhaps 6 or more settlement groups. I think that the NTRT thread might also have some? Do these groups ever share information or views? Should they?

    Started by Rob79, 8th September 2014 14:03
    2 Pages
    1 2
    • Replies: 10
    • Views: 1,883
    10th September 2014 08:37 Go to last post
  20. APN Question

    I was told that although APN's can be sent to people HMRC haven't been given royal assent to take the money or assets if not paid.... Is this true?

    Started by Monster, 6th August 2014 20:44
    • Replies: 6
    • Views: 2,080
    8th September 2014 13:57 Go to last post

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