BIG GROUP

[ChimpMaster]

Please read the whole thing in context.

If you settle with HMRC and pay tax now for a liability that was due at an earlier time, then interest is payable.

If you pay the 2019 charge on the loan balance for that earlier year, then if you pay the 2019 charge at the right time, no interest is due. You may however pay more tax perhaps (depends on circumstances).

It may also be the case that even if you pay the 2019 charge, HMRC will continue to chase the earlier liability.

One way of looking at the 2019 charge is that it's an APN on all those schemes that did not and cannot get an APN for whatever reason.

Something seems amiss with the part I've put in bold. Why would HMRC tax you with a Loan Charge in 2019, and then request tax on an earlier liability? That would count as double taxation. If you have a loan of say £100k and have to pay ~£50k tax (@45% plus NI) in 2019 on it, what else is left for HMRC to try and squeeze out of you?

[eek]

Something seems amiss with the part I've put in bold. Why would HMRC tax you with a Loan Charge in 2019, and then request tax on an earlier liability? That would count as double taxation. If you have a loan of say £100k and have to pay ~£50k tax (@45% plus NI) in 2019 on it, what else is left for HMRC to try and squeeze out of you?

The line in bold probably should have been read with the one below it..

It may also be the case that even if you pay the 2019 charge, HMRC will continue to chase the earlier liability.

One way of looking at the 2019 charge is that it's an APN on all those schemes that did not and cannot get an APN for whatever reason.

HMRC will avoid double taxation but I wouldn't be surprised if they went for every variation of charge that they could plausibly get aware with short of double taxation....

Remember there is a structural deficit in Government finances which needs to be plugged and they will be trying any legitimate means possible to maximise their tax take..

[starstruck]

It may also be the case that even if you pay the 2019 charge, HMRC will continue to chase the earlier liability.

Even if these years are closed?

[webberg]

Something seems amiss with the part I've put in bold. Why would HMRC tax you with a Loan Charge in 2019, and then request tax on an earlier liability? That would count as double taxation. If you have a loan of say £100k and have to pay ~£50k tax (@45% plus NI) in 2019 on it, what else is left for HMRC to try and squeeze out of you?

Because if the liability is properly due in an earlier year, then HMRC has a DUTY to try and collect it (and interest etc).

The 2019 charge will still apply unless the tax has been settled/paid for the year the loan balance relates to.

Obviously will apply to closed years.

[webberg]

Even if these years are closed?

Obviously not.

The issue of closed/open has been discussed a lot in this forum.

A closed year is not able to be reopened by HMRC. However the 2019 charge will not discriminate.

[starstruck]

Obviously not.

The issue of closed/open has been discussed a lot in this forum.

A closed year is not able to be reopened by HMRC. However the 2019 charge will not discriminate.

It's all so confusing and seemingly contradictory - it's easy to get lost sometimes. What's obvious to you isn't to me. Thanks for the reply.

[ChimpMaster]

Obviously not.

The issue of closed/open has been discussed a lot in this forum.

A closed year is not able to be reopened by HMRC. However the 2019 charge will not discriminate.

This is where this gets interesting (or confusing, depending on your perspective ).

You cannot settle a closed year because there is no tax/interest due on it because it is, well, closed.

However, the 2019 Loan Charge will still apply to closed years, but this is as you say like an APN.... so HMRC are collecting tax that isn't really tax. It's a payment on account of some sort, or so it seems. In the twisted world of HMRC, do they magically take this Loan Charge payment and deem it to be the tax you "should" have paid, so now you've paid the Charge we will let you off...?

Tell you what Webberg, I loved studying Tax at University and I still enjoy delving into it, but I don't envy the job you have to do here

At least it's Friday and almost wine-o-clock

[stonehenge]

I am sure HMG/HMRC see the 2019 loan charge as a way of drawing a line under all of this.

It will enable them to tax everyone, who hasn't already settled, all the way back to 1999. It's a bit of a master stroke really.

Why on earth would they bother continuing to chase people once they've collected the charge?

I could state the bloomin' obvious but that sort of talk is not welcome around here.

[webberg]

As I posted in a separate thread, Big Group is moving to a last call for its plan to resolve the tax position for its members.

Existing members have been told that the final opt in date is:

8th December 2017

We remain open for new joiners until Christmas.

If you wish to join up to then, we will extend the opt in deadline by a couple of weeks from joining in order to be able to explain fully and clearly what we are doing.

[luxCon]

Plan

Any details on what the plan, steps, and possible outcome/ conclusions are?

Not sure without some sort of framework any new member can establish suitability.