Churchill Knight & Boox clients being investigated as Managed Service Companies

[Fred Bloggs]

The bit I don't get is that they are now too late for the 2017/18 tax year and you would have thought that given the more obvious examples we all know about I would have expected way more than 2 firms to be included in these test cases.

Just playing a longer game? Or sheer incompetence WRT sticking to a time frame that caught earlier years? Either is plausible. Unfortunately, for those now in the crossfire, it's largely academic at the moment.

[eek]

Just playing a longer game? Or sheer incompetence WRT sticking to a time frame that caught earlier years? Either is plausible. Unfortunately, for those now in the crossfire, it's largely academic at the moment.

I can't see a longer game because HMRC hardly need any bigger ammo to work with ( at the moment determine salary v dividends is seemingly enough to be an MSC). So it's either something in the portals has annoyed them or incompetence.

And I don't buy the incompetence as by only starting a case against just 2 firms HMRC have lost the opportunity to recover a significant £x0ms+ from other firms.

[enda1]

Anyone an idea of timeline in all this? When can we expect each step to be resolved?

[GregRickshaw]

That might well be a deliberate part of the strategy. To see how far Hector can stretch the MSC legislation before a tribunal pushes back. It wouldn't surprise me at all if there is a list of candidate accountant firms with a risk rating against them.

That is and interesting take on it and I suspect the truth especially considering what we have seen of the wording of the captures (apart from the fee Point (a)). Boox and CK have been caught very differently in fact CK's condition (d) was 'after speaking with clients' so you could argue anecdotal?

[jamesbrown]

Anyone an idea of timeline in all this? When can we expect each step to be resolved?

Assuming a FTT, UTT and potentially beyond, perhaps 5-10 years.

[cojak]

No idea at all.

[enda1]

Assuming a FTT, UTT and potentially beyond, perhaps 5-10 years.

Thanks for your reply. But I meant more in terms of each step. There are multiple gateways to pass through before (if it gets to) tribunal. When should the next one be?

[cojak]

Thanks for your reply. But I meant more in terms of each step. There are multiple gateways to pass through before (if it gets to) tribunal. When should the next one be?

No idea at all.

[eek]

Anyone an idea of timeline in all this? When can we expect each step to be resolved?

Based on CBS (and this could well be worse as waiting times have worsened since then).

Initial appeal letters - Now (deadline is approaching)
2024/5 - First Tribunal
2025/7 - Upper Tribunal
2027/9 - appeal court.

Now the first tribunal may be quicker and that would shorten the other deadlines but HMRC don't usually rush these things (longer delays = more pressure resulting in people paying).

[enda1]

Based on CBS (and this could well be worse as waiting times have worsened since then).

Initial appeal letters - Now (deadline is approaching)
2024/5 - First Tribunal
2025/7 - Upper Tribunal
2027/9 - appeal court.

Now the first tribunal may be quicker and that would shorten the other deadlines but HMRC don't usually rush these things (longer delays = more pressure resulting in people paying).

I guess the first step should be the appeal (which most have probably launched).

Then if this is not favourable there is the option of a "review" which should be concluded within 45 days:
https://www.gov.uk/tax-appeals/revie...nalty-decision
"Reviews usually take 45 days, but HMRC will contact you if it will take longer."

Then there's the dreaded tribunals...


Hopefully at least some of us can get out via the initial appeal and review channels. Let's see.