Settlement Opportunity

[WalterWhite]

Yep.

I think they would struggle with this at this moment in time - unless of course Rangers goes their way. Even thst could be argued it was because of miss-management

[LandRover]

HMRC have to cite a case that reflects the one you were/are using to issue a FN though....

Isn't ToAA - Transfer of Assets Abroad that HMRC will directing their attack against?

Transfer of assets abroad: contractors and EBTs

[WalterWhite]

Isn't ToAA - Transfer of Assets Abroad that HMRC will directing their attack against?

Transfer of assets abroad: contractors and EBTs

They can do, yes. However it depends if the intermediary was offshore or not. If the intermediary was/is UK based then TOAA is not applicable

[SimonJones]

They can do, yes. However it depends if the intermediary was offshore or not. If the intermediary was/is UK based then TOAA is not applicable

The ToAA legislation is going to confusing yet interesting, because, The Isle of Man is a dependency of the British crown, and is not a part of the UK or EU.

[LandRover]

The ToAA legislation is going to confusing yet interesting, because, The Isle of Man is a dependency of the British crown, and is not a part of the UK or EU.

"Mr Boyle was liable to income tax in respect of the arrangements by virtue of the transfer of assets provisions in IRC v Brackett; Brackett v Chater (Inspector of Taxes); Chater (Inspector of Taxes) v Brackett 60 TC 134."

Will HMRC reference BOYLE in their Follower Notice?

https://www.gov.uk/government/upload...-f-notices.pdf

"Follower notices can be issued to taxpayers who have used an avoidance scheme which has been shown in another taxpayer’s litigation to be ineffective."

[AnotherContractor]

Settlement Conundurm

In the "Without Prejudice" settlement statement the HMRC have underestimated the loans I've actually received.

If I accept their estimate will/can they ask to see proof i.e. bank statements etc ?

[webberg]

Isn't ToAA - Transfer of Assets Abroad that HMRC will directing their attack against?

Transfer of assets abroad: contractors and EBTs

That's not a case but a change of law.

There was an argument and case about the application of the retrospection but that is NOT the substantive tax issue and as such is not relevant to Follower Notices.

[webberg]

The ToAA legislation is going to confusing yet interesting, because, The Isle of Man is a dependency of the British crown, and is not a part of the UK or EU.

Yes indeed. This is being tested in the Fisher case so watch that we interest.

[regron]

So we have a few cases to keep an eye on. Anyone got a rough idea when next stages are due to be heard ?

Fisher ? (ToAA)
Rangers ? (EBT)
Ingenious ? (APN JR)

[webberg]

So we have a few cases to keep an eye on. Anyone got a rough idea when next stages are due to be heard ?

Fisher ? (ToAA)
Rangers ? (EBT)
Ingenious ? (APN JR)

Fisher - perhaps qtr 2 2016
Rangers - perhaps qtr 4 2015
Ingenious - hearing concludes this month, JR next month. decision on both perhaps late 2015

Worth mentioning that Huitson will be out any day.

Also De Silva (for some people the antithesis of Cotter) will be due soon.