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Loans write off and APNs

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    #21
    Originally posted by DealorNoDeal View Post
    Unfortunately, I can't see HMRC agreeing to close that open enquiry unless you settle.

    I assume you are aware that no additional interest will have accrued since you paid the APN.
    Even if Higgs and/or Hoey put an end to the ToAA and s687 arguments? I'm not familiar with the specifics of Edge but I assume that HMRC would run the same argument(s)?

    I can't see why anyone would settle ahead of those being decided, especially if there is no financial penalty in waiting given the APN prevents interest accruing.

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      #22
      Originally posted by Ozbird View Post
      How can I find that out? The employer was Edge Consulting and they no longer exist.
      The reality is that you won't be able to find out whether a deduction has already been claimed without involving HMRC.

      But whether or not Edge Consulting has claimed the deduction is not the question. That it is whether it is "deductible" and you'd need to understand the full facts and then analyse the scheme from a tax perspective to find out whether it is. My view of the reality is that remuneration is deductible in almost all circumstances (there is a question of when it is deductible). For example, have a look at some of the recent GAAR panel decisions where the panel says "this dodgy scheme doesn't work, the amount is taxable on the employee and so deductible for the employer".

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        #23
        Originally posted by Iliketax View Post
        The reality is that you won't be able to find out whether a deduction has already been claimed without involving HMRC.

        But whether or not Edge Consulting has claimed the deduction is not the question. That it is whether it is "deductible" and you'd need to understand the full facts and then analyse the scheme from a tax perspective to find out whether it is. My view of the reality is that remuneration is deductible in almost all circumstances (there is a question of when it is deductible). For example, have a look at some of the recent GAAR panel decisions where the panel says "this dodgy scheme doesn't work, the amount is taxable on the employee and so deductible for the employer".
        Edge Consulting became Redstone. You can still email Redstone and ask the questions. Whilst they admit to knowing nothing if you push them they seem to be able to find out the information for you. I have an email. queries@redstoneservices.co.uk

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