I am aware of much adverse criticism here and other social media recently, usually based on inaccurate assumptions and/or driven by unknown motivations.
Quite why WTT Big Group is expected to reveal, in public, details of its strategy when others have not, leads me to question why those “others” think it so important. I will be generous and assume that there is some genuine concern for the welfare of all contractors which is somehow served by giving HMRC a heads up on how we will move forward. I do however respectfully disagree that sharing information here about how we advance is sensible.
There is a further suggestion that unless we use our clients’ money to support the inevitable Hoey appeal, we will be forever blocked from advancing. This raises two points. In regard to financial support, we have previously offered discussions as to the form and conditions of such support when it was advertised that the UTT hearing might require such. We were told initially than some tens of thousands of pounds were required only to be told 72 hours later (over a weekend) that the funding gap had been closed. The caveats we would have sought over any assistance did not get discussed. This time around, we contacted the law firm last Friday and as the main person there was busy in Court that day, suggested that he call us when free. We have had no call. We’re not sure what to read into that.
The claimed blocking or binding that would occur if Hoey loses, is not something that we or our legal team consider possible. If Mr Hoey loses it will be on the facts in his case and based on the arguments he raised. Another case taken on different facts and different arguments cannot be blocked and can be bound only if the there are sufficient similarities. We are of the view that we have significantly different facts and arguments.
Will we share those? Yes, at the appropriate time and with the appropriate parties. The appropriate time/parties are when asked by a client: when in conference with Counsel: when directed by a Tribunal. Our clients remain fully briefed of our arguments through provision of several technical papers, countless webinars and ongoing updates. To suggest they don’t know what they’re paying for does them a disservice. We encourage clients to do their research and arrive at an informed decision before joining us.
A few months ago HMRC attempted to stop one of our cases by citing Hoey and arguing that we would be repeating the arguments. Therefore, HMRC claimed, we should be “stayed” behind the final decision in Hoey. Our counter to that argument was subject to a “direction” from Judge Gillett – the same Judge who decided the Hoey case at FTT. Judge Gillett refused HMRC’s application and indicated that our action should proceed as it was raising points not discussed in Hoey. We consider that proof enough that our arguments differ sufficiently from those in Hoey.
There is also some concern that WTT has profited (and perhaps is profiteering) by its use of a group model. I respectfully suggest that you visit the early posts in the Big Group thread. Joining Big Group always carried a fee plus a monthly fee. The first joining fee was £50. That fee has increased as our strategy absorbed more Counsel time and it was considered fair that later joiners – who benefit from that work – should contribute more.
Where BG clients needed other services, with the exception of tax return preparation or matters unrelated to their use of arrangements, we have provided these for no additional cost. Where individuals have asked us to help on issues, but have not immediately joined Big Group, we have charged a fee. If they subsequently join Big Group, the fee paid is a credit against the joining fee.
The £15 plus VAT is the same for all. Whilst I wish we had client numbers as suggested in the rather frenzied posts here, we do not. The monthly payments do not cover our overheads. For those we depend on the above additional work, developing services via our SRA Regulated law firm and other activities, including working on tax disputes outside the contracting sector. Do not mistake WTT and its reported financial position as being those of Big Group – different enterprises.
I note with some pride that the group subscription model has been adopted by others (at a higher monthly cost). This is sensible as otherwise individual contractors cannot meet the hourly rates of the experts needed.
Every client in Big Group and every client who has engaged us for other services, has had the benefit of a free initial call. Those who join (and we actively discourage some as we either do not have the skills they need or it is too soon for them to join us) have had the benefit of nearly six years of advice delivered via personal contact, webinar, newsletters, physical conferences or personal email. All those who have joined are able to contact me or my fellow directors or my senior staff. All those who joined are able to be part of other strategies (hedging their bets) or leave if they wish, without penalty.
We have remained true to the original purpose of Big Group. It is a RESOLUTION exercise.
Initially we collected data on schemes and made a case with HMRC that a reasonable settlement could be achieved if all parties were willing to be sensible. It became obvious after our HMRC contact was moved at short notice to film work, that HMRC was not interested. We moved into political lobbying and spent hundreds of hours with MPs. This included attending the House of Lords to give evidence. This effort failed to produce significant change (other than many Treasury MPs being castigated and censored). It also proved to be the catalyst for the formation of LCAG. Following this, we decided to focus on litigation which was always being worked on in the background. All of these are part of a RESOLUTION process – the entire purpose of Big Group.
In seeking that resolution we have made repeated calls for those involved in the advisory side, to come together and combine forces. Every one of those calls has been unsuccessful. This is unfortunate as perhaps if we were aware of the arguments on Hoey – before appearing in Tribunal – and had had an opportunity to have some input, we may have a better idea now of whether that case deserves support.
In all of the above, WTT Big Group and all its people have been transparent in its purpose and motives. We have explained – often too much – why we do things and have demonstrated that we have nothing to hide. Of course that leads us open to accusation, unfounded or otherwise, and left us as an easy target for those with motives we can only guess at.
Finally, we are “accused” of being too close to CUK and of using the forum as a recruiting tool. Our client base shows that around 10% of current clients heard about us via CUK, the rest coming either directly or from their pre-existing advisers. The present very unprofessional posts in the “professional” forum perhaps demonstrate that the moderators here have no special place for WTT.
Everybody who uses these forums is here because the tax analysis they were “assured” was correct – even “approved” – turned out to be wrong. Surely the lesson there is that those here, including me, who assert that certain things must be correct, need to be treated with a degree of caution. Tax “experts” in this space have been proven wrong before and may well be again. If you choose to believe one view over another, then do so with knowledge, research and some due diligence.
Regardless, it appears that the environment here is no longer conducive to those of us who have poured hundreds of hours into trying to help. Whilst I and many others may not have expected thanks, I think we might have expected a degree of respect. That has temporarily at least departed. I will therefore also depart as an active poster.
My clients know where to find me.
I wish you all good fortune in whatever result you are hoping for.
Quite why WTT Big Group is expected to reveal, in public, details of its strategy when others have not, leads me to question why those “others” think it so important. I will be generous and assume that there is some genuine concern for the welfare of all contractors which is somehow served by giving HMRC a heads up on how we will move forward. I do however respectfully disagree that sharing information here about how we advance is sensible.
There is a further suggestion that unless we use our clients’ money to support the inevitable Hoey appeal, we will be forever blocked from advancing. This raises two points. In regard to financial support, we have previously offered discussions as to the form and conditions of such support when it was advertised that the UTT hearing might require such. We were told initially than some tens of thousands of pounds were required only to be told 72 hours later (over a weekend) that the funding gap had been closed. The caveats we would have sought over any assistance did not get discussed. This time around, we contacted the law firm last Friday and as the main person there was busy in Court that day, suggested that he call us when free. We have had no call. We’re not sure what to read into that.
The claimed blocking or binding that would occur if Hoey loses, is not something that we or our legal team consider possible. If Mr Hoey loses it will be on the facts in his case and based on the arguments he raised. Another case taken on different facts and different arguments cannot be blocked and can be bound only if the there are sufficient similarities. We are of the view that we have significantly different facts and arguments.
Will we share those? Yes, at the appropriate time and with the appropriate parties. The appropriate time/parties are when asked by a client: when in conference with Counsel: when directed by a Tribunal. Our clients remain fully briefed of our arguments through provision of several technical papers, countless webinars and ongoing updates. To suggest they don’t know what they’re paying for does them a disservice. We encourage clients to do their research and arrive at an informed decision before joining us.
A few months ago HMRC attempted to stop one of our cases by citing Hoey and arguing that we would be repeating the arguments. Therefore, HMRC claimed, we should be “stayed” behind the final decision in Hoey. Our counter to that argument was subject to a “direction” from Judge Gillett – the same Judge who decided the Hoey case at FTT. Judge Gillett refused HMRC’s application and indicated that our action should proceed as it was raising points not discussed in Hoey. We consider that proof enough that our arguments differ sufficiently from those in Hoey.
There is also some concern that WTT has profited (and perhaps is profiteering) by its use of a group model. I respectfully suggest that you visit the early posts in the Big Group thread. Joining Big Group always carried a fee plus a monthly fee. The first joining fee was £50. That fee has increased as our strategy absorbed more Counsel time and it was considered fair that later joiners – who benefit from that work – should contribute more.
Where BG clients needed other services, with the exception of tax return preparation or matters unrelated to their use of arrangements, we have provided these for no additional cost. Where individuals have asked us to help on issues, but have not immediately joined Big Group, we have charged a fee. If they subsequently join Big Group, the fee paid is a credit against the joining fee.
The £15 plus VAT is the same for all. Whilst I wish we had client numbers as suggested in the rather frenzied posts here, we do not. The monthly payments do not cover our overheads. For those we depend on the above additional work, developing services via our SRA Regulated law firm and other activities, including working on tax disputes outside the contracting sector. Do not mistake WTT and its reported financial position as being those of Big Group – different enterprises.
I note with some pride that the group subscription model has been adopted by others (at a higher monthly cost). This is sensible as otherwise individual contractors cannot meet the hourly rates of the experts needed.
Every client in Big Group and every client who has engaged us for other services, has had the benefit of a free initial call. Those who join (and we actively discourage some as we either do not have the skills they need or it is too soon for them to join us) have had the benefit of nearly six years of advice delivered via personal contact, webinar, newsletters, physical conferences or personal email. All those who have joined are able to contact me or my fellow directors or my senior staff. All those who joined are able to be part of other strategies (hedging their bets) or leave if they wish, without penalty.
We have remained true to the original purpose of Big Group. It is a RESOLUTION exercise.
Initially we collected data on schemes and made a case with HMRC that a reasonable settlement could be achieved if all parties were willing to be sensible. It became obvious after our HMRC contact was moved at short notice to film work, that HMRC was not interested. We moved into political lobbying and spent hundreds of hours with MPs. This included attending the House of Lords to give evidence. This effort failed to produce significant change (other than many Treasury MPs being castigated and censored). It also proved to be the catalyst for the formation of LCAG. Following this, we decided to focus on litigation which was always being worked on in the background. All of these are part of a RESOLUTION process – the entire purpose of Big Group.
In seeking that resolution we have made repeated calls for those involved in the advisory side, to come together and combine forces. Every one of those calls has been unsuccessful. This is unfortunate as perhaps if we were aware of the arguments on Hoey – before appearing in Tribunal – and had had an opportunity to have some input, we may have a better idea now of whether that case deserves support.
In all of the above, WTT Big Group and all its people have been transparent in its purpose and motives. We have explained – often too much – why we do things and have demonstrated that we have nothing to hide. Of course that leads us open to accusation, unfounded or otherwise, and left us as an easy target for those with motives we can only guess at.
Finally, we are “accused” of being too close to CUK and of using the forum as a recruiting tool. Our client base shows that around 10% of current clients heard about us via CUK, the rest coming either directly or from their pre-existing advisers. The present very unprofessional posts in the “professional” forum perhaps demonstrate that the moderators here have no special place for WTT.
Everybody who uses these forums is here because the tax analysis they were “assured” was correct – even “approved” – turned out to be wrong. Surely the lesson there is that those here, including me, who assert that certain things must be correct, need to be treated with a degree of caution. Tax “experts” in this space have been proven wrong before and may well be again. If you choose to believe one view over another, then do so with knowledge, research and some due diligence.
Regardless, it appears that the environment here is no longer conducive to those of us who have poured hundreds of hours into trying to help. Whilst I and many others may not have expected thanks, I think we might have expected a degree of respect. That has temporarily at least departed. I will therefore also depart as an active poster.
My clients know where to find me.
I wish you all good fortune in whatever result you are hoping for.
Comment