BN66 - Round 2 (Court of Appeal)

[KiwiGuy]

your thoughts

with the election being hung, i sort of thing this bodes well for us as either party is getting into bed with Lib Dems, whom are opposed to BN66, so yes hold of the letters for now, but i will be certainly be sending a friendly remindered to Ed Davie

[DonkeyRhubarb]

Not entirely different I think, judgement turned on scheme must stand up to commercial scrutiny, although this is not mentioned in the law. MontP had an identical scheme. Their letter of yesterday acknowledges KPMG case, and simply instructs to pay HMRC.

Consider this.

The KPMG version of the RDS scheme was worth £156M. The judgment acknowledges there were several other promoters, one of which we know was Montp. The value to HMRC was probably about the same as the double tax scheme ie. £200M or so.

So, why did they take this one through the Tax Courts and not our case?

ANSWER: because the legal opinion they got on the RDS scheme must have indicated that they had a prospect of winning.

So what does this tell you about all the legal opinions they got on our scheme (of which I know there were several)?

[DonkeyRhubarb]

If the person from the other side wants to get in touch again discretely you can use this 100% secure (it's German!) anonymous email service:

German Privacy Foundation

This also accepts small attachments.

If you use the following email address it will redirect to my personal email account.

[email protected]

[Slobbo]

Did anyone ask the SNP what their view on BN66 is ?

My wife contacted the SNP and they haven't bothered to respond to her questions. Unfortunately we got our top notch helpful Lib Dem MP replaced with a Labour knob. I live up north and seem to be surrounded by morons that can't see the damage labour have done to the UK.

[Buzby]

Snp

My wife contacted the SNP and they haven't bothered to respond to her questions. Unfortunately we got our top notch helpful Lib Dem MP replaced with a Labour knob. I live up north and seem to be surrounded by morons that can't see the damage labour have done to the UK.

I wrote to my local SNP MP and I had a good reply:

"The retrospective action to be taken by HM Treasury in light of the legislation is appalling and I feel greatly for you and your family. I will certainly take this matter up with the Chancellor of the Exchequer and press your points in the strongest terms. As soon as a reply is to hand I will be back in touch"

He got back in, but will wait to see what happens in London before next move.

[hobnob116]

Ebt

Hi

I've been following this thread for a while now and I wanted to thank you all for syndicating the info that has appeared here.

Can anyone explain the essential difference between EBTs that are to be ended from 2011 (as per PBR), and the schemes that are being pursued in the courts?

[Buzby]

ebt

Hi

I've been following this thread for a while now and I wanted to thank you all for syndicating the info that has appeared here.

Can anyone explain the essential difference between EBTs that are to be ended from 2011 (as per PBR), and the schemes that are being pursued in the courts?

BN66 is about double taxation (see http://www.bn66.co.uk for more details). no loans, money paid every month using the double taxation agreement which was legal until BN66 changed the law retrospectively.

[Buzby]

bn66

BN66 is about double taxation (see Budget Note 66 (BN66) – Double Taxation Treaty Abuse for more details). no loans, money paid every month using the double taxation agreement which was legal until BN66 changed the law retrospectively.

sorry, here is a better link for more information on BN66:

BN66 - Wikipedia, the free encyclopedia

[Alba]

Finance Bill measures need proper scrutiny or commitment to revisit

My wife contacted the SNP and they haven't bothered to respond to her questions. Unfortunately we got our top notch helpful Lib Dem MP replaced with a Labour knob. I live up north and seem to be surrounded by morons that can't see the damage labour have done to the UK.

Nice to see that they need so little time to review important country matters!
Following this afternoon’s announcement that the Finance Bill will get just three hours of debate in the House of Commons tomorrow during the parliamentary ‘wash-up’, the Chartered Institute of Taxation’s Tax Policy Director, John Whiting, said:
“It is deeply unsatisfactory for such a lengthy Finance Bill to have so little debate in Parliament.
“There will be no opportunity to review the clauses of the Bill properly for technical defects prior to debate in Parliament. There will be no opportunity to press ministers for clarification on most of the Bill’s contents. There will be no chance to discuss how most of these detailed technical proposals will work in practice.
“If the Government are set on pressing ahead with a substantial Finance Bill then we would like them to give a categorical assurance – which we hope the opposition parties will endorse – that there will be a willingness to return to some elements of the Bill later in the year if technical or practical problems are detected by the tax profession.”
The CIOT would normally submit full analysis of the bill’s clauses to interested parties – government, opposition parties and tax authorities. Initial analysis shows that there are a number of areas that need proper scrutiny: in some cases the measures are new; others have been consulted on but there has been little proper response; others simply do not need to be passed in a hurry.
John Whiting continued:
“We are not seeking to delay necessary legislation but simply arguing for proper scrutiny. The Government should withdraw many clauses from the current Bill – or the opposition parties should not allow them to proceed. Instead, they should be brought back after the election when they can be fully debated and scrutinised.”
Notes to Editors
The CIOT is calling for, at a minimum, the following clauses to be dropped from the Finance Bill and brought back after the election when they can be fully debated and scrutinised:
• Clause 24 (& schedule 3) Pensions
• Clauses 31-33 (& schedules 7-9): Charities
• Clause 36 (& Schedule 11) Penalties: offshore income etc
• Clause 56 SDLT: partnerships
• Clause 57 (& Schedule 18) Disclosure of tax avoidance schemes (DOTAS
• Clause 58 Security for payment of PAYE

[smalldog]

bye bye lurch!!

Good riddens Timms!!!! you total ahole