The Hoey appeal has been listed on 28 March 2022, for 5 days.
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Hoey appeal listed
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I've dipped in to day 4 of the appeal (Hoey (claimant/appellant) & ors v Her Majesty’s Revenue & Customs (defendant/respondent) - YouTube).
Am I right to feel that HMRC are getting a bit of a grilling and are fluffing it a bit?
About 2:45 into the stream there are some references to the "End User" and what responsibility they have for using TP services which may have challenging (challengeable) tax setups - One of these "End Users" I worked for was HMRC! One of the reasons I thought I was on safe ground with MTM/ Montpelier...
Anyone else work at HMRC or other Govt Depts? Does this matter?
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I've been enjoying the Armadillo tweets even though I don't understand 99% of what's going on -
https://twitter.com/ArmadilloSupprt/...37561683431432Comment
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Seems like the judges want to side with HMRC on the PAYE issue who say they have a discretion apparently allowed in a manual that no-one is allowed to see that contradicts what is in the public manual. Essentially the judges want to find in favour of HMRC because they don't like tax avoidance rather than based on the actual law.Comment
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See the Costello case and the massive extension to what the definition of an MSC is...Originally posted by dammit chloe View PostSeems like the judges want to side with HMRC on the PAYE issue who say they have a discretion apparently allowed in a manual that no-one is allowed to see that contradicts what is in the public manual. Essentially the judges want to find in favour of HMRC because they don't like tax avoidance rather than based on the actual law.merely at clientco for the entertainmentComment
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A crown court judge siding with the crown prosecutors? Whatever next eh?!Originally posted by dammit chloe View PostSeems like the judges want to side with HMRC on the PAYE issue who say they have a discretion apparently allowed in a manual that no-one is allowed to see that contradicts what is in the public manual. Essentially the judges want to find in favour of HMRC because they don't like tax avoidance rather than based on the actual law.Comment
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