Self Assessment Tax Return 2018/19 and Loan Charge

[webberg]

If we listened to Matt Hall over the last 18 months there would have been no political progress made at all. He believed only litigation of schemes could save anyone.

That said, we have to be realistic about JRs and their historical success on tax issues, but there may well be a tipping point and the indiscriminate application of the Loan Charge could be it. It can also be viewed as simply another possible line of attack.

There are also other aspects to this which are more closely guarded.

I agree that success rates of JRs against HMRC are very low. In our view money and energy was better directed at the sort of lobbying done so effectively by LCAG and their supporters.

Unfortunately, many promoters talked up JRs as a means of (in my view) distracting attention away from the question of how the substantive issue of potential liability would be dealt with. Now that we see many of the JRs falling away and exposing the question of whether a liability exists or not, we also see calls for funds to press on with the litigation. What's more a litigation that some will propose be based on the original analysis which has been widely discredited in the cases that have been heard.

[starstruck]

If we listened to Matt Hall over the last 18 months there would have been no political progress made at all. He believed only litigation of schemes could save anyone.

That said, we have to be realistic about JRs and their historical success on tax issues, but there may well be a tipping point and the indiscriminate application of the Loan Charge could be it. It can also be viewed as simply another possible line of attack.

There are also other aspects to this which are more closely guarded.

Yeah sorry, I certainly wasn't saying listen to MH, it was the legal case that he was referencing that I thought would be of interest. I can see in there all the main arguments against the LC that we have expressed over the years and the judge pretty much dismissed them all and said there is nothing wrong with retrospection when dealing with tax avoidance and it doesn't breach your human rights (my paraphrasing).