As we advertised, we met with HMRC this week.
We are preparing our own summary of the discussion (3 and half hours) and will post this to the Big Group private forum in due course.
Headlines;
1. HMRC is keen to settle and is happy to discuss ideas other than their own current analysis.
2. CLSO take up was reasonable but HMRC is now sorting those who did not settle, by scheme, with a dedicated senior officer and will be looking to push to litigation/settlement. We indicated a number of reasons why BG members did not take up the offer, which was well received.
3. Post 2011 schemes still lack detail and data and are not likely to be seeing a Tribunal soon
4. The recent prejudicial requests for returns/information are not intended to create jeopardy for contractors and we are in the process of agreeing a suitable and centralised means of responding
5. HMRC is happy for WTT to act as a central contact for all Big Group members (with some minor admin to be done) and has offered to put us in touch with the theme lead for each scheme investigation.
6. The interaction between APN teams and DMB was not acting as they were advised it would and they will investigate. Issues of bankruptcy were also raised and some clarity offered.
7. HMRC indicated that the end of the formal settlement process (CLSO) would now mean that only individual or group "contract" settlements, would be available. Since confirmed in today's Accountancy Age.
8. They mentioned that the Boyle case was considered to have very limited application due to its facts. They were not able to comment on Murray Group.
As mentioned, we're writing up a summary and we will in due course have agreed minutes. I suspect that we will not release the minutes due to confidentiality issues.
The overall impression is that HMRC is genuinely looking to resolve issues and welcome the presentation of differing analysis for the tax treatment.
It would, however, be fair to say that nothing conclusive was agreed or suggested as being better than that view for the moment.
Overall a very positive meeting for Big Group members and a lot to follow up on.
We are preparing our own summary of the discussion (3 and half hours) and will post this to the Big Group private forum in due course.
Headlines;
1. HMRC is keen to settle and is happy to discuss ideas other than their own current analysis.
2. CLSO take up was reasonable but HMRC is now sorting those who did not settle, by scheme, with a dedicated senior officer and will be looking to push to litigation/settlement. We indicated a number of reasons why BG members did not take up the offer, which was well received.
3. Post 2011 schemes still lack detail and data and are not likely to be seeing a Tribunal soon
4. The recent prejudicial requests for returns/information are not intended to create jeopardy for contractors and we are in the process of agreeing a suitable and centralised means of responding
5. HMRC is happy for WTT to act as a central contact for all Big Group members (with some minor admin to be done) and has offered to put us in touch with the theme lead for each scheme investigation.
6. The interaction between APN teams and DMB was not acting as they were advised it would and they will investigate. Issues of bankruptcy were also raised and some clarity offered.
7. HMRC indicated that the end of the formal settlement process (CLSO) would now mean that only individual or group "contract" settlements, would be available. Since confirmed in today's Accountancy Age.
8. They mentioned that the Boyle case was considered to have very limited application due to its facts. They were not able to comment on Murray Group.
As mentioned, we're writing up a summary and we will in due course have agreed minutes. I suspect that we will not release the minutes due to confidentiality issues.
The overall impression is that HMRC is genuinely looking to resolve issues and welcome the presentation of differing analysis for the tax treatment.
It would, however, be fair to say that nothing conclusive was agreed or suggested as being better than that view for the moment.
Overall a very positive meeting for Big Group members and a lot to follow up on.
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