Originally posted by bluemonkey71
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Settlement Opportunity
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Originally posted by WalterWhite View PostHMRC have to cite a case that reflects the one you were/are using to issue a FN though....
Transfer of assets abroad: contractors and EBTsComment
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Originally posted by LandRover View PostIsn't ToAA - Transfer of Assets Abroad that HMRC will directing their attack against?
Transfer of assets abroad: contractors and EBTsComment
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Originally posted by WalterWhite View PostThey can do, yes. However it depends if the intermediary was offshore or not. If the intermediary was/is UK based then TOAA is not applicableComment
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Originally posted by SimonJones View PostThe 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.
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."Comment
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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
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Originally posted by LandRover View PostIsn't ToAA - Transfer of Assets Abroad that HMRC will directing their attack against?
Transfer of assets abroad: contractors and EBTs
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
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Originally posted by SimonJones View PostThe 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.Best Forum Adviser & Forum Personality of the Year 2018.
(No, me neither).Comment
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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
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Originally posted by regron View PostSo 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)
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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