HMRC Enquiries: Bedouin/Redstone

[webberg]

Totally agree!

This is why I think it dosen't matter whether the SRN is specified in the return or not, providing the scheme was registered.

This is why I find it difficult to understand that where SRN is specified, discovery is void!

We use a SELF assessment system.

That means YOU are responsible for YOUR tax affairs.

Reliance upon other parties, including HMRC, to join the threads together to paint a picture of your tax position is unacceptable. YOU have to supply the data.

If HMRC get the information more than once = no problem.

If HMRC don't get it = YOUR problem as you have failed in SELF assessment.

If you're relying on adequate declaration to protect from discovery, you MUST have shown the SRN.

[webberg]

Be very careful with "Discovery".

Charlton/Corfield is from 2012 and there have been cases since that have both supported that decision and said it's not relevant.

A case from around the same time (Anthony While) contains a neat summary of what discovery meant then.

In particular it was confirmed that Discovery could mean that the original HMRC Inspector could have changed his mind or that a new Inspector has a different view.

If that happens, then the only defence is to show that a) you supplied EVERYTHING needed and b) the Inspector could NOT have logically reached any decision other than the original one.

Both difficult tests.

Perhaps a better and more up to date read is Cotter (be warned that this is not really about discovery but has some interesting points) and De Silva. The latter is heading for a higher Court.

[EBTContractor]

^ webberg

In these cases where BIK, dotas number etc were all disclosed (in my case edge/norla) shouldnt you have argued 2 years ago when HMRc sent the discovery notice that they have nothing new to discover?

A new inspector would have reached the same conclusion.

I should have just told them to foxtrot oscar and not appealed the discovery assessments.

IF they send me an APN I'll write back and argue nothing new to discover and please, please will you all just get farked and spend your efforts on real evasion, money laundering, human trafficking, tackling poverty, potholes, urban fox problems etc...

[webberg]

In these cases where BIK, dotas number etc were all disclosed (in my case edge/norla) shouldnt you have argued 2 years ago when HMRc sent the discovery notice that they have nothing new to discover?

A new inspector would have reached the same conclusion.

I should have just told them to foxtrot oscar and not appealed the discovery assessments.

IF they send me an APN I'll write back and argue nothing new to discover and please, please will you all just get farked and spend your efforts on real evasion, money laundering, human trafficking, tackling poverty, potholes, urban fox problems etc...

certainly tempting.

Unfortunately 2 years ago discovery was still being developed and the concept was introduced of the "hypothetical HMRC officer who is averagely competent". In a lot of cases since HMRC has said that its officers are not "averagely competent" and have "discovered" that a decision was incorrect.

Judges have agreed!

the key point I was trying to make though is that relying on HMRC to join the dots in terms of what they knew is a hopeless argument. If YOU have not been very specific, it's a hard battle.

[EBTContractor]

^ webberg

Of course. And we all know hmrc makes up their own rulea as they go along.

In hindsight i wish i hadn't been scared into appealing the amount, instead i should have questioned their sanity and below average intelligence.

do you know if hmrc has sent out apns for norla/edge users?

[InNZ]

do you know if hmrc has sent out apns for norla/edge users?

Please don't tempt fate

[Michael J Perry FCA]

Edge APN advance notice letters

Please don't tempt fate

HMRC started sending out letters last week to give advance notice of APN's to be issued in the next 1 to 8 weeks.

[porrker]

I received a demand for Tax for year 2011-2012 which I wrote back to HMRC challenging their demand. I received my self assessment statement today and the demand is on the statement is this correct or should I call HMRC?

[p1clw]

So

Had a initial letter blah blah "I estimate" blah blah "We Believe" so sent the standard letter for appeal

a few weeks ago had a statement with the same numbers

Now I get a letter saying...

Blah blah "You are currently in the very small minority of people who have not paid us yet

Please Ring us......."

Nothing about appealing or my first letter

Do they really think people believe this stuff

[malvolio]

So

Had a initial letter blah blah "I estimate" blah blah "We Believe" so sent the standard letter for appeal

a few weeks ago had a statement with the same numbers

Now I get a letter saying...

Blah blah "You are currently in the very small minority of people who have not paid us yet

Please Ring us......."

Nothing about appealing or my first letter

Do they really think people believe this stuff

So

So what?

Yes, they do. You play by their rules or not at all, as far as they are concerned. So try phoning them...