Murray Group (Rangers) tax case - decision today?

[DotasScandal]

HMRC would always appeal until the very top if necessary, they have unlimited resources for it.

And these unlimited resources = our own money. Ain't it a beautiful system?

[webberg]

NTRT(TAA) raised a damn good pot. Will big group be able to do the same? If 3,000 put in £200 they would be up and going.

Good question.

There is a limit to what I'm willing to share here in terms of strategy but which I will explore and explain in the Big Group forum.

However, from conversations with BG members, there is an appetite for litigation and a willingness to pay modest sums to fund it.

Bear in mind that BG seeks to identify the common parts of the various structures and argue those rather than detail and as such members of scheme A will have a vested interest in fighting an attack on scheme B, most of the time.

Is litigation our primary aim? No. HMRC's resources are getting more stretched and we continue to believe that there is yet more mileage there. That journey has an important test next week.

Will we NEVER litigate? No. We will litigate where we have to although at the moment we see that as being selective.

3,000 at £200 each is a formidable number. Is it enough? Perhaps. Are we willing to expose our members to an open ended cheque? No.

The lessons from NTRT are valuable and the work done there to keep it on track and moving forward remarkable. If BG can emulate that for those impacted not by a single issue but by many diverse issues, we will have done well.

[webberg]

apologies if already posted

On EBTs and Rangers FC – Part 1 | Waiting for Godot

[webberg]

No appeal and this becomes very useful for hmrc, any similar schemes may be target of follower notices. Perhaps this was the aim of hmrc, as why keep going when they lost at ftt and then upper tribunal, they knew one decision in their favour would result in Murray group administrator having to fund an appeal, which is highly unlikely with no funds.

One possibility is that Murray Group, strapped as it is for cash, will not have the resources or appetite for an appeal to Supreme Court.

In that case, whilst the decision will hold sway for a period, it might still be trumped by a Supreme Court decision elsewhere.

It's also the case however that the decision is for PAYE regulations. NOT individual tax. As such it may be the case that the question coming from the Chancellor on Monday morning to HMRC is:

"Well done chaps. When can I expect to see the several million PAYE receipts?"

Response is perhaps:

"Ermm. the company has no money and we might get a few pence in the pound"

Chancellor: "Never mind, as long as we get back the legal costs and can now chase all those other employers who used something similar. When and how much?"

HMRC; "Ermm, may not cover the legal costs. We can go back only 4 years and most of these schemes ended in 2011. Most "employers" have disappeared."

Chancellor: "Not good. But we can still chase individuals for money? When and how much?"

HMRC; "Ermm, not with this decision probably. Need to wait for an individual one, say 5 years"

Chancellor: "Report to the Headmaster's Study and expect no mercy!!"

[chubacabra]

One possibility is that Murray Group, strapped as it is for cash, will not have the resources or appetite for an appeal to Supreme Court.

In that case, whilst the decision will hold sway for a period, it might still be trumped by a Supreme Court decision elsewhere.

It's also the case however that the decision is for PAYE regulations. NOT individual tax. As such it may be the case that the question coming from the Chancellor on Monday morning to HMRC is:

"Well done chaps. When can I expect to see the several million PAYE receipts?"

Response is perhaps:

"Ermm. the company has no money and we might get a few pence in the pound"

Chancellor: "Never mind, as long as we get back the legal costs and can now chase all those other employers who used something similar. When and how much?"

HMRC; "Ermm, may not cover the legal costs. We can go back only 4 years and most of these schemes ended in 2011. Most "employers" have disappeared."

Chancellor: "Not good. But we can still chase individuals for money? When and how much?"

HMRC; "Ermm, not with this decision probably. Need to wait for an individual one, say 5 years"

Chancellor: "Report to the Headmaster's Study and expect no mercy!!"

Oh it would make me chuckle if this is the case

[DotasScandal]

On EBTs and Rangers FC – Part 1 | Waiting for Godot

Part 2 was supposed to be out today...
Mr Maugham is being a tease

[webberg]

Tease no longer

Waiting for Godot

[ASB]

There is a lot of generally interesting stuff on his blog as well.

[webberg]

Yes there is.

I lifted (with his permission) a set of questions to ask yourself if offered ANYTHING that reduced tax and which in now enshrined elsewhere here.

The think to bear in mind however is that as he admits, he makes a living defending or prosecuting tax schemes and as such is not a disinterested party.

Personally I think he presents arguments in a balanced manner and declares his interest so as long as you make allowance for the motive, his words make a valuable contribution.

[webberg]

Accountancy Age is reporting that reaction amongst advisers is mixed.

They quote a lawyer from Pinsent Masons saying "we're doomed" and a salesman from Rebus as saying that all EBT/EFURB schemes are bust and will be terminated with APN and Follower Notices.

They quote Jolyon Maugham based on his blog articles.

Stripped of hyperbole I think the Pinsent Masons' reasoning is debatable, Rebus' missing and Maugham's perhaps too "form over substance".

I was alarmed that Linkedin was apparently quoting an umbrella company operator as saying all contractor EBT schemes were doomed but actually it was linking to the Pinsent opinion piece.

It was curious that the 6 page spread in the Sunday Times on footballers being pursued for £100m created more column inches than the Murray case. Or was it?