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Settlement Opportunity

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    Originally posted by bluemonkey71 View Post
    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

    Comment


      Originally posted by WalterWhite View Post
      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
      http://www.dotas-scandal.org LCAG Join Us

      Comment


        Originally posted by LandRover View Post
        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

        Comment


          Originally posted by WalterWhite View Post
          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.

          Comment


            Originally posted by SimonJones View Post
            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."
            http://www.dotas-scandal.org LCAG Join Us

            Comment


              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 ?

              Comment


                Originally posted by LandRover View Post
                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.
                Best Forum Adviser & Forum Personality of the Year 2018.

                (No, me neither).

                Comment


                  Originally posted by SimonJones View Post
                  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.
                  Best Forum Adviser & Forum Personality of the Year 2018.

                  (No, me neither).

                  Comment


                    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)
                    STRENGTH - "A river cuts through rock not because of its power, but its persistence"

                    Comment


                      Originally posted by regron View Post
                      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.
                      Best Forum Adviser & Forum Personality of the Year 2018.

                      (No, me neither).

                      Comment

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