BN66 - Round 2 (Court of Appeal)

[SantaClaus]

When that much mis-used word "fairness" comes up at the Court of Appeal hearing, I wonder how this article will rest with the judge's decision:

Secrecy deal with Switzerland could let Britons avoid £40bn in taxes

"Wealthy Britons could dodge £40bn in tax payments after the UK agreed ahead of negotiations on a tax deal with Switzerland that the country could maintain its traditional banking secrecy."

and get this...

"Proposals to make the deal retrospective were also rejected by the Swiss authorities, saving further large sums for wealthy UK residents."

http://www.guardian.co.uk/business/2...land-agreement

So basically, the govt. have more or less said it's fine to evade taxes by stashing your money in a Swiss bank account, but it's not ok to use a tax avoidance scheme which has been fully declared on your tax return.

Shouldn't HMRC be pursuing £40bn of unpaid evaded taxes, as opposed to an alleged £200M of legally avoided taxes???

P.S. HMRC, don't forget to read this one out in court!

[Squicker]

I suspect he is going to plague us for the next few weeks.

Are people happy to ignore him or do you feel it's time to do something about it?

Ignore him, I don't know him or anything about him, he just comes across as a mental old twat. There's **** all some forum junky can do to influence our course anyway. Whatever is said here, by him or anyone else, is meaningless, repudiatable tosh.

[helen7]

Pensions are now classed as tax avoidance

It seems that HMRC now feel pensions are tax avoidance.

Premier League stars using loophole to save millions in tax - Premier League, Football - The Independent

Onwere, who works at Thomas Eggar solicitors, said that there were fears among players that changes to the rules could be retrospective and claw back money already put into trusts by players.

Seems we may have some very wealthy friends who would have an interest in retrospective tax being abolished.

[SantaClaus]

It seems that HMRC now feel pensions are tax avoidance.

Premier League stars using loophole to save millions in tax - Premier League, Football - The Independent

Onwere, who works at Thomas Eggar solicitors, said that there were fears among players that changes to the rules could be retrospective and claw back money already put into trusts by players.

Seems we may have some very wealthy friends who would have an interest in retrospective tax being abolished.

This is why our case is so important to HMRC. If we lose, then it opens the floodgates for retrospective tax on everything.

[TykeMerc]

This is why our case is so important to HMRC. If we lose, then it opens the floodgates for retrospective tax on everything.

Which is a major reason I've supported your case.

I don't happen to agree with the tax planning approach you folks took as I felt it was overly risky when I considrered it as an option some years ago.
However retrospective legislation is just plain wrong in my book. There's a huge difference between saying as of date XX/YY this loophole will be closed and as of XX/YY/ZZ (when ZZ is in the past) this loophole was closed but we didn't bother to tell any bugger so invented a time machine.

[DonkeyRhubarb]

Which is a major reason I've supported your case.

I don't happen to agree with the tax planning approach you folks took as I felt it was overly risky when I considrered it as an option some years ago.
However retrospective legislation is just plain wrong in my book. There's a huge difference between saying as of date XX/YY this loophole will be closed and as of XX/YY/ZZ (when ZZ is in the past) this loophole was closed but we didn't bother to tell any bugger so invented a time machine.

I notice how promoters of other schemes have been quick to dismiss BN66 as being specific to double taxation treaties and offshore trusts, and of no relevance to their arrangements.

However, this seems like wishful thinking to me.

I'm sure HMRC don't see it like this and I bet they can't wait to exploit the precedent this would set.

[BolshieBastard]

Here's something for the HMRC team to read out in court.

Philip Gershuny, tax partner at the law firm, Hogan Lovells, said: “If Wayne Rooney’s image rights are owned by a company, then he could well save several million pounds of tax. This is the total sum which would be saved over the duration of his new contract if he takes advantage of a legal loophole, allowing him to pay just 28 per cent corporation tax on image rights payments instead of the regular 50 per cent tax for high earners."

Sound familiar you bunch of tossers? Let me repeat it for you LEGAL LOOPHOLE

How Wayne Rooney could score multi-million pound tax cut – Telegraph Blogs

[DonkeyRhubarb]

CoA timetable

I'm still waiting to hear if it will start tomorrow or Wednesday.

It will probably last 3 days.

PwC are expecting to be up first but this is also yet to be confirmed.

I will provide an update as soon as I hear anything.

[helen7]

Do we have people going along to give us play by play forum updates?

During the last hearing I think this thread had hundreds of watchers.

[DonkeyRhubarb]

Do we have people going along to give us play by play forum updates?

During the last hearing I think this thread had hundreds of watchers.

I expect the turnout to be pretty low this time. I know someone, who will be there for most of it, who has agreed to update me but it won't be a blow-by-blow commentary.

To be honest, if last time is anything to go by, the Judges won't give much away.

You can come out of these hearings feeling fairly positive and then get the worst judgment imaginable.