Sanzar Partnership? New IOM company

[Bradley]

s720 ITA 2007

Paul

How does the scheme purport to get round s720 ITA 2007?

Do you have a UK scheme number?

How can they be employees and get a share of the profits as partners? Is it a partnership with trusts as partners? The "employees" are beneficiaries of the trusts?

Hi
My name is Paul Mihailovits, I am the Managing Director of The Sanzar Partnership in the Isle of Man. As The Sanzar Partnership is being discussed here, I thought I should respond to try to clear up some of the general misconceptions that exist....

[dude69]

can't say I understand this. You pay income tax on income. UK Corporation Tax imputes basic rate income tax. If you haven't paid any UK Corporation Tax, there is nothing to impute.

There is a new scheme where foreign dividends will come basic rate imputed, but only for amounts under £5k/year where you hold less than 10% of the company equity.

http://www.pwc.com/uk/budget/2007/an...dividends.html

[contractorbob]

New IOM company

Hi,

I made the mistake of joining a similar scheme provided by Steed Solutions ltd. I am also under investigation and know a few other people in a similar situation with MTM. I actually spoke to the HMRC tax inspector who told me that they are currently in the process of preparing test cases in order to set a precedent. It could take a very long time for these cases to be resolved resulting in very high interest charges if the decision goes in favour of HMRC. As far as I can see, the only prudent course of action is to make a payment on account to stop the accumulation of interest charges. Either that or just hope that HMRC lose their case.

Is any one else in the same situation? Does anyone know anything more about these cases? Dose anyone else have a different plan for avoiding bankruptcy?

[ASB]

As far as I can see, the only prudent course of action is to make a payment on account to stop the accumulation of interest charges. Either that or just hope that HMRC lose their case.

There used to be - and may still be - a thing called something like "certificate of tax deposit". This enabled a taxpayer to make a contingent payment against the disputed liability. I don;t think a simple payment on account works with regard to stopping the interest clock ticking.

[BrilloPad]

Hi,

I made the mistake of joining a similar scheme provided by Steed Solutions ltd. I am also under investigation and know a few other people in a similar situation with MTM. I actually spoke to the HMRC tax inspector who told me that they are currently in the process of preparing test cases in order to set a precedent. It could take a very long time for these cases to be resolved resulting in very high interest charges if the decision goes in favour of HMRC. As far as I can see, the only prudent course of action is to make a payment on account to stop the accumulation of interest charges. Either that or just hope that HMRC lose their case.

Is any one else in the same situation? Does anyone know anything more about these cases? Dose anyone else have a different plan for avoiding bankruptcy?

I kinow some people in IOM schemes who have received no challenge to their tax return for certain years. My understanding is that the IR are dragging their heels and the IOM schemes are trying to push the test case forward.

[ChimpMaster]

I kinow some people in IOM schemes who have received no challenge to their tax return for certain years. My understanding is that the IR are dragging their heels and the IOM schemes are trying to push the test case forward.

Why would the IOM schemes want to push this forward? After all, even if the schemes are valid today, HMRC would simply change the rules next year to stop them all operating.

A lot pf people I know were with Steed too. None of them seem too worried, though obviously now that the scheme has shut down they have all moved on.

[BrilloPad]

Why would the IOM schemes want to push this forward? After all, even if the schemes are valid today, HMRC would simply change the rules next year to stop them all operating.

A lot pf people I know were with Steed too. None of them seem too worried, though obviously now that the scheme has shut down they have all moved on.

Bigger question - why are the IR delaying?

There are 2 ways the scheme can close :-
1. its declared closed - that means it was legal
2. IR wins legal case

[tim123]

Bigger question - why are the IR delaying?

There are 2 ways the scheme can close :-
1. its declared closed - that means it was legal

No, it means nothing of the sort. I means that the Scheme's operators closed it before the issue was dedcided.

tim

[BrilloPad]

No, it means nothing of the sort. I means that the Scheme's operators closed it before the issue was dedcided.

tim

Is this Steed?

[contractorbob]

Partnership? New IOM company

The scheme that I was with is Steed. Also, I have confirmed with HMRC that making payments on account will stop interest incurring on any tax that may be owed. I have also confirmed that such payments would be refunded (including interest) should a final ruling go against HMRC. Having said that, HMRC may well take this as far as the house of lords so it could take a while for this to happen.

The main motivation for making a payment on a account is to avoid a very nasty surprise in a few years time if HMRC win. By that stage the effect of interest on the unpaid tax could be crippling.

I would be really interested to know what other people are doing.