LC, APN - despair ?

[headspin]

"MPs are very good at making HMRC see sense."

Are you joking

You're aware of the APPG letters? and the individual letters many prominent MPs are sending Bojo and the Saj aren't you

[BrilloPad]

You're aware of the APPG letters? and the individual letters many prominent MPs are sending Bojo and the Saj aren't you

And that has made how much difference to HMRC?

[stonehenge]

Worst case?

HMRC claim that the arrangement does not do what it says on the tin and that the original loan remains reportable (and has not been).

Further the replacement loan does not meet the alleged criteria and is also reportable (and has not been).

Further, the arrangement is a linked tax avoidance mechanism which is reportable (and has not been) and may also have been disclosable for DOTAS - by the user given the offshore connection - and has not been.

All of those carry penalties.

I confess that whilst we have the materials that Vanquish and connections made available to some clients who expressed an interest, we have not delved deep into the inner workings and technical claims because standing back and looking at the whole, we became very uneasy. In short the risk of a GAAR applying seemed to us to be sufficiently high so as to prevent us recommending use of the scheme by our clients, even with caveats.

Very good points.

Given that it attempts to circumvent primary anti-avoidance legislation (LC) it would seem especially vulnerable to the GAAR.

It's definitely on the upper end of the risk scale.