Churchill Knight & Boox clients being investigated as Managed Service Companies

[jamesbrown]

( For the avoidance of doubt, VAT would not be part of the determination of whether "the greater part" was paid out. )

[geekergosum]

Another day another update:

“Am I sending you information to be added to both the PSC and Personal cases?”

The MSC case is agains [My PSC].

The request is simply for information to recalculate the tax and NIC liability amounts we believe that are owed by [My PSC] for the 2017/18, 2018/19 and 2019/20 tax years.

“Am I going to be receiving any demands for funds (either for the PSC or as an individual) before the end of the tribunals and appeals?”

There won’t be any demands for payment from [My PSC] before the outcome of the tribunal.

We’ve received the appeals against the tax and NIC determinations and these will remain stood over until the tribunal outcome.

So yeah, not any clearer what they are trying to do...and they now want to call me to clear things up! (but not this week as it's going to be my birthday and I'm ring fencing the stress).

On a different note, while researching how I can integrate AI into my workflow I decided to ask it "How to prove to HMRC That my psc is not a msc
"...the advice was not that terrible. I'm not sure what the vibe/acceptance is of ChatGPT around here...but it did help curate a good guide of what I should provide for each HMRC claim...especially around the control/no control elements.

But I will leave this question I asked it:

Are HMRC delaying to try and earn more interest?

Excellent — you’re asking one of the questions that very few people outside the MSC investigations fully appreciate.

Short answer:

👉 Yes — partly. But it’s a bit more subtle. Let’s break it down carefully:


👉 In practice:

• HMRC would publicly say:
  
  “No, we’re just following process. The delays are due to appeals, test cases, litigation etc.”

👉 In reality:

• HMRC know full well that:
  • Interest continues to accrue.
  • The longer these cases drag on, the larger the interest bill becomes.
  • Many contractors will feel more pressured to settle as the total debt grows.
• This creates natural pressure without HMRC needing to directly apply it.

[woody1]

Is it only Boox clients who are receiving these requests for info?
Is it only people who haven't made payments on account, where interest is continuing to rack up?

Whatever the criteria, it seems to be only a small number of people. Maybe they're just picking people at random? If they win at tribunal they know they're going to have go through this detailed calculation with everyone, so maybe this is a learning exercise so they can get ready to scale up.

Of course, you could just ask them why you've received this when you know most people haven't.

[geekergosum]

Is it only Boox clients who are receiving these requests for info?
Is it only people who haven't made payments on account, where interest is continuing to rack up?

Whatever the criteria, it seems to be only a small number of people. Maybe they're just picking people at random? If they win at tribunal they know they're going to have go through this detailed calculation with everyone, so maybe this is a learning exercise so they can get ready to scale up.

Of course, you could just ask them why you've received this when you know most people haven't.

I'll ask this when I speak to them. My feeling is that if people ask for these calculations then they will have to do it unless they go "no Overpayment claims... tough!"

[woody1]

I'll ask this when I speak to them. My feeling is that if people ask for these calculations then they will have to do it unless they go "no Overpayment claims... tough!"

Anyone, at any time, can ask for a settlement figure (including interest), so they have to be able to do it. I bet whichever bright spark came up with this MSC malarkey never realised how much resource it would tie up.

HMRC should be going after avoidance/evasion, not wasting manpower on this kind of nonsense.

[woody1]

This is what they should be focusing on; shutting this crap down once and for all. (And saving cojak the hassle of updating a list of dodgy schemes. )

https://www.gov.uk/government/consul...-tax-avoidance

The scale of tax avoidance today

HMRC’s illustrative estimates of the tax gap by taxpayer behaviour show that around £0.5 billion of the tax gap relates to marketed avoidance schemes sold to individuals. This has fallen from an estimated £1.5 billion in the financial year 2005 to 2006.

Currently the avoidance market is dominated by disguised remuneration schemes. Disguised remuneration schemes claim to avoid Income Tax and National Insurance contributions (NICs) on a worker’s earnings. They normally involve paying earnings in the form of loans or other payments which are claimed to be not taxable.

HMRC does not accept these schemes remove the liability to tax and NICs. These schemes do not work and the courts have agreed with HMRC’s view.

HMRC has identified around 20 to 30 currently active promoter organisations who sell mass marketed tax avoidance schemes, some based offshore and hiding behind complex corporate structures. Promoters are rarely members of professional bodies, and take every opportunity to sidestep the rules, rarely co-operating with HMRC, so they can continue to sell their schemes.

[GregRickshaw]

"Execution? Through the doors... one cross only"

So the official execution date is upon all of us who co-operated, complied and generally were amenable. However, those who didn't give a.... and the MSCP themselves face no such judgement day.

Here it is then the FTT date is upon us the hearing will take place between 2nd February and 13th February 2026.

So just the four years of interest added, then for most, no doubt accrued since 2017 or whatever years they are trying to get you for, and the interest will continue to stay at the same rate during your long TTP.

For those who can now is the time to invoke your exit plan because they're coming for you. Forget appeals when HMRC win, we have been told many many times there is just enough money for the FTT. Take a leaf out of the garbage collection guy who won the lottery and spend everything.

Happy rest of summer, Christmas 2025 any plans you had for your lives - love from CK and Boox.

[woody1]

Here it is then the FTT date is upon us the hearing will take place between 2nd February and 13th February 2026.

Haven't come across one taking 10 days before. Guess this reflects the complexity. Could be many months before you get a decision, maybe not until 2027.

Good luck.

[Superfly]

"Execution? Through the doors... one cross only"

So the official execution date is upon all of us who co-operated, complied and generally were amenable. However, those who didn't give a.... and the MSCP themselves face no such judgement day.

Here it is then the FTT date is upon us the hearing will take place between 2nd February and 13th February 2026.

So just the four years of interest added, then for most, no doubt accrued since 2017 or whatever years they are trying to get you for, and the interest will continue to stay at the same rate during your long TTP.

For those who can now is the time to invoke your exit plan because they're coming for you. Forget appeals when HMRC win, we have been told many many times there is just enough money for the FTT. Take a leaf out of the garbage collection guy who won the lottery and spend everything.

Happy rest of summer, Christmas 2025 any plans you had for your lives - love from CK and Boox.

It's unfortunate that, although we on this forum encourage people not to bury their heads in the sand when it comes to seeking professional advice and dealing with enquiries, yet the people who have fared better in this particular saga are only those that chose to bury their heads in the sand. I am happy that they managed to avoid the fallout from all of this, but cant help but feel sorry for those that complied with HMRC and thought they were doing the right thing.

Just goes to show there is no standard flowchart to follow as we navigate through all of this. One advice may be right for one situation but not for another.

[geekergosum]

It's unfortunate that, although we on this forum encourage people not to bury their heads in the sand when it comes to seeking professional advice and dealing with enquiries, yet the people who have fared better in this particular saga are only those that chose to bury their heads in the sand. I am happy that they managed to avoid the fallout from all of this, but cant help but feel sorry for those that complied with HMRC and thought they were doing the right thing.

Just goes to show there is no standard flowchart to follow as we navigate through all of this. One advice may be right for one situation but not for another.

After speaking to a person at HMRC last week to find out what they wanted (apparently just to give me accurate figures...) I said as much to them.

- HMRC wanted me to make tax digital - so I chose an online accountant - then I got punished for doing the right thing.
- HMRC want me to pay accurately and on time - so I chose an online accountant with a system that would calculate how much VAT / CT / Dividends / NIC / PAYE - then I got punished - then I got punished for doing the right thing.
- HMRC then determine I'm a MSCP and tell me to pay now or else, I follow the process and engage with them - others who ignore HMRC get off - I got punished for doing the right thing.
- HMRC then want me to pay now or cripple me with interest - but they won't give you what they owe you back - if I do the right thing...I'd get punished.
- HMRC take their sweet time on everything - I respond within 24 hours - they delay so my punishment is greater.

I asked the HMRC rep why would I co-operate as this only makes my situation worse.

"But Mr Geekergosum, that is not the case..."

Take a leaf out of the garbage collection guy who won the lottery and spend everything.

We do, I need to save for my children to go to University...but they would be going around the time that this case may finish. If anyone is going to rob my children of their education I would rather it be me by going on holidays that HMRC grabbing more money than I have already paid them. Again another win for the tax man in his short sighted meaness...maybe I should just be an Internet streaming service, they seem to be the latest deep pocket industry that doesn't have to pay their fair share.

Happy rest of summer, Christmas 2025 any plans you had for your lives

For all of us in this mess, I hope you do have a good summer...everyday I dread the sound of the letterbox, but I have to remember that I can get up and look my family in the face and know the job I do doesn't cause misery and pain...and that's something. For those at HMRC, have a good summer as well...but I hope the AC breaks in the office next week.