Originally posted by starstruck
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We started with the idea that in almost all circumstances, "loans" were in fact remuneration and as such if the employer had not deducted tax then HMRC could and should have issued assessments on them.
How that theory fits into and disrupts (or not) the blizzard of legislation we have seen since 2011 is a lot of work and analysis.
There are a number of cases coming to FTT this year which will be arguing the above or variants. Even though many promoters (if they are still around) claim that their original analysis (usually based on Sempra and/or Dextra - now determined by the Supreme Court to have been incorrectly decided) is good, there is evidence that they are all gravitating towards the above.
So, Big Group is not a secret. We will tell you what we're planning before we ask for a fee. We will not go into detail because as mentioned, that has been paid for by existing members, but the big picture is definitely not a secret and not something we keep in order to sell.
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