BIG GROUP

[Iter]

Wouldn’t they still need to have an open enquiry/ assessment as well for it to be considered protected!

[Finalwhistle]

Wouldn’t they still need to have an open enquiry/ assessment as well for it to be considered protected!

it appears not. Their response is it doesn't matter whether they have an open enquiry or not, the year 2014/05 is included as a protected year (and interest will be added). I'll let you know what comes back from tomorrows call. But I shall now be armed with my "what happens after Friday then?".

[Albert49]

it appears not. Their response is it doesn't matter whether they have an open enquiry or not, the year 2014/05 is included as a protected year (and interest will be added). I'll let you know what comes back from tomorrows call. But I shall now be armed with my "what happens after Friday then?".

If you have loans for 2014/15 I would avoid asking that question until late next week, if you ask tomorrow, I wouldn't put it past them sending you an S9A letter with Friday's date on...

[Finalwhistle]

If you have loans for 2014/15 I would avoid asking that question until late next week, if you ask tomorrow, I wouldn't put it past them sending you an S9A letter with Friday's date on...

It was an anonymous call (unless they automatically track my mobile number to my account).

[Finalwhistle]

It was an anonymous call (unless they automatically track my mobile number to my account).

Right here we go...(phone call received from HMRC)

HMRC have included the year 2014/15 (whether it is protected or unprotected) as it is within their 6 year enquiry window working 6 years back from the current tax year (18/19, which confusingly applies to 2012/13 however they've applied to 14/15).

As Webberg states as of this Friday we are in the next tax year and as such 2014/15 is no longer in the 6 year enquiry window. HMRC would have covered their back by saying that the LC kicks in on Friday anyway such that everything is 'protected' (and interest applied). However for those going through the settlement process the LC does not kick in on Friday... which leaves open an opportunity (?) to argue that 2014/105 is no longer within the enquiry window.

[sunilthakur007]

BIG GROUP

I am IN and would like to join .

[webberg]

I am IN and would like to join .

Thank you.

Call us to arrange a discussion before you make a final decision - it's free.

[Sunflowers]

Open years

If you have only closed (unprotected) years then a win for us at litigation means no tax for you.

What about in the case of all years being open (protected)?

[webberg]

What about in the case of all years being open (protected)?

Which post is that from please?

Context is king here.

If our litigation is successful, no tax will be due. Period.

I suspect the quote you make is about discovery or some such?

[Sunflowers]

Open years...

If you have only closed (unprotected) years then a win for us at litigation means no tax for you.

Will we win?

No guarantee of that. We have a confidence level of 65%.

Speak to other advisers and they may be 65% sure that we'll lose. Speak to HMRC and they will be 100% sure we'll lose.

I cannot be any more clear.

In terms of a JR against the loan charge, I think we know of at least 4 going ahead of which LCAG is one.

Will they defeat the loan charge?

I don't know.

Every message from Government is that the loan charge is here to stay, but it would not a shock if they held the line until the last possible second and then caved as that seems to be what passes for policy for this Government (and the last one and all the ones before then).

Hi webberg, the question about open years is in relation to the above comment

If you have only closed (unprotected) years then a win for us at litigation means no tax for you.

All my years have a discovery assessment. So all 7 are open. Thanks.