SP Management - HMRC claims

[HelenF]

Hi,

Has anyone actually used Carnegie Knox to appeal to these HMRC notices? If so, would anyone be willing to share the appeal? Carnegie are offering to appeal on behalf of clients (at a cost of course) however they are being very vague on what the basis of the appeal is, only advising it is "generic".
Also, does anyone know if they have had a tax counsels' opinion on their scheme?

Thank you.

As i have my own tax firm i could sound biased so id suggest you use absolutely anybody other than Carnegie. They are AML. Their appeal will almost certainly be drafted by a barrister named Setu Kamal but im not sure as i havent seen it, though he does most of their work. HMRC are never going to look at any appeal coming from the very people that create tax schemes to this day very well.

[eek]

As i have my own tax firm i could sound biased so id suggest you use absolutely anybody other than Carnegie. They are AML. Their appeal will almost certainly be drafted by a barrister named Setu Kamal but im not sure as i havent seen it, though he does most of their work. HMRC are never going to look at any appeal coming from the very people that create tax schemes to this day very well.

Slightly unfair on HMRC, they will look at the appeal and start tearing it apart line by line, word by word for funsies.

the reality is that hmrc will probably ignore all appeals but someone else looking at things afresh may identify a reason or at least not annoy HMRC quite as much.

[HelenF]

Slightly unfair on HMRC, they will look at the appeal and start tearing it apart line by line, word by word for funsies.

the reality is that hmrc will probably ignore all appeals but someone else looking at things afresh may identify a reason or at least not annoy HMRC quite as much.

lol i get your point. Lets have our own fun at expense of HMRC. ill provide the OP a free appeal if they wish. Lets see how that pans out Sir/Madam. I know thats inappropriate but hey....we live in ridiculous times so sod them. Lets do this, we are on same team.

[DealorNoDeal]

I'd say it's highly unlikely the scheme would stand up at a tax tribunal. I've never come across one yet that has. HMRC are currently very hot on anything loan related, and apparently approval has been given at the highest level to use discretionary powers under s684 to clobber schemes:
https://forums.contractoruk.com/hmrc...eme-years.html

Realistically, the best that could probably be hoped for by lodging an appeal is delaying having to settle. But delaying comes at a significant cost now that interest rates have shot up.