Churchill Knight & Boox clients being investigated as Managed Service Companies

[WTFH]

Can you explain this point for me. I am confused why you think it has always been a rock solid win for HMRC. My attorneys and pretty much everyone on this forum were saying that HMRC are wrong and we should all contest it. My attorneys have always maintained very confidently that HMRC are wrong.

You've mentioned "my attorneys", now if you mean a solicitor, then you're paying £300-600 per hour for their advice.
I would like to offer some advice for free: put that £300-600 into HMRC to start reducing your bill, it's not going to go away without you paying.

[woody1]

I think there's a slim chance this may not go HMRC's way. Whilst it's true that they've won all contractor tax avoidance cases over the past couple of decades, these were cases involving contrived (mainly offshore) tax avoidance schemes. Even the CBS MSC case, which HMRC are spring boarding off, was an Isle of Man tax avoidance scheme. I don't think CK/Boox could be classed as a contrived scheme.

But I do say slim chance. It's a massive uphill battle going up against HMRC in court. Fine for big corporates in VAT cases but the odds are heavily stacked against ordinary folks.

Anyway, it will be interesting to see how this pans out.

[eek]

I think there's a slim chance this may not go HMRC's way. Whilst it's true that they've won all contractor tax avoidance cases over the past couple of decades, these were cases involving contrived (mainly offshore) tax avoidance schemes. Even the CBS MSC case, which HMRC are spring boarding off, was an Isle of Man tax avoidance scheme. I don't think CK/Boox could be classed as a contrived scheme.

But I do say slim chance. It's a massive uphill battle going up against HMRC in court. Fine for big corporates in VAT cases but the odds are heavily stacked against ordinary folks.

Anyway, it will be interesting to see how this pans out.

HMRC have selected / agreed what the example / test cases will be - as I said earlier today those cases are going to be the easily won ones

[woody1]

HMRC have selected / agreed what the example / test cases will be - as I said earlier today those cases are going to be the easily won ones

OK, extremely slim chance.

Nevertheless, as GregRickshaw said, it's not really worth settling at the moment while there is a chance, no matter how slim.

[woody1]

[HUMOUR]
I wonder if a bookmaker would take a bet on the outcome? By betting on HMRC to win, you could hedge your liability. Although I imagine the odds might be very short.
[/HUMOUR]

[SwissSaffa]

So now I am worried.

Would anyone mind explaining to me how the payment plans work with HMRC:

1. How do they determine whether you can pay it off in payments?
2. How do they calculate the interest?
3. How do they determine the length of the payment plan
4. How do they determine the monthly payment amount?

[woody1]

So now I am worried.

Would anyone mind explaining to me how the payment plans work with HMRC:

1. How do they determine whether you can pay it off in payments?
2. How do they calculate the interest?
3. How do they determine the length of the payment plan
4. How do they determine the monthly payment amount?

1. If you ask for a payment plan (time to pay), you'll usually get one.
2. Interest is accrued from the date the liability first arose. You'll also continue to pay interest for the duration of the payment plan (I think they call it forward interest). You can find their interest rates here:
https://www.gov.uk/government/public...interest-rates
It's pretty scary from 6 Apr 2025: bank base + 4%
3&4. This is based on what you can afford. 5 years is not too difficult to get. Some people have obtained 10 years, and I've even heard of 20 years.

The interest is why many people will have made payments on account (PoA). Making a PoA stops further interest accruing.

[SwissSaffa]

5 years is not too difficult to get.

This is at least reassuring. I am so screwed now. There goes the hope of buying a flat. This is so ironic. I literally just got into a salary bracket that I can afford a flat.

[SwissSaffa]

I guess there is also a small chance my solicitor might fight it as they represent dozens or more of contractors in the exact same position.

[SwissSaffa]

The interest is why many people will have made payments on account (PoA). Making a PoA stops further interest accruing.

Do you have to have the full amount on account or what is the minimum amount you should have on account?