Churchill Knight & Boox clients being investigated as Managed Service Companies

[jamesbrown]

Listening to the IPSE webinar with Paul Mason (Markel Tax), their view is that (2)(b), (2)(c) and (2)(d) are most at risk here. Their view is that there's a clear link to services in (2)(a), so an annual fee paid monthly wouldn't be enough.

[stuckWithCK]

Listening to the IPSE webinar with Paul Mason (Markel Tax), their view is that (2)(a), (2)(b) and (2)(c) are most at risk here. Their view is that there's a clear link to services in (2)(a), so an annual fee paid monthly wouldn't be enough.

So it is encouraging for ones received letter under 61B(2) (CK clients)?

[jamesbrown]

So it is encouraging for ones received letter under 61B(2) (CK clients)?

Not especially, just that the argument for (2)(a) looks particularly weak where there is no evidence of a payment linked to service provision, merely an annual fee split into monthly payments. Apologies, I had a typo in my original post, which you quoted (now fixed). As to whether a dormant company rate is a sufficient link, probably not, but that remains TBD.

[superdoodle]

Can anyone listen to the IPSE webinar?

[GregRickshaw]

Listening to the IPSE webinar with Paul Mason (Markel Tax), their view is that (2)(b), (2)(c) and (2)(d) are most at risk here. Their view is that there's a clear link to services in (2)(a), so an annual fee paid monthly wouldn't be enough.

Not sure where (b) has come from since I last looked?

CK were caught on (a) (c) and (d) no mention of (b).

So if IPSE think (a) is pretty much defunct then CK clients need to fight only (c) and (d) and from what I have seen CK clients are not caught anywhere even close by (c) and (d).

If (a) is weak as IPSE think then this is different to what the others think.

Which rather than making me feel good makes me wonder how any of them can argue a away easily without huge confusion.

[DealorNoDeal]

There's always a chance they have got it wrong so it depends on your thinking, is it worth it?

Absolutely, it's worth putting forward your case against MSC in your appeal. I'm just not sure it's worth paying an advisor £hundreds to do it for you. If history is anything to go by, once you engage some advisors, they see you as a cash cow.

But maybe I'm just a cynical bastard who only sees leeches preying on people.

[jamesbrown]

Not sure where (b) has come from since I last looked?

CK were caught on (a) (c) and (d) no mention of (b).

So if IPSE think (a) is pretty much defunct then CK clients need to fight only (c) and (d) and from what I have seen CK clients are not caught anywhere even close by (c) and (d).

If (a) is weak as IPSE think then this is different to what the others think.

Which rather than making me feel good makes me wonder how any of them can argue a away easily without huge confusion.

Right, (2)(c) and (2)(d) are the most important in relation to CK and Boox, unless the dormant company rate is sufficient for (2)(a) with CK, but I doubt it. Of those, I think (2)(c) is most at risk because there is a line between advice about tax efficient options and default assumptions that need to be explicitly overridden. We shall see. Anyway, the "others" to whom you refer seem to be in the minority from the seminars I have attended so far. I think it was just David Kirk & Co arguing for (2)(a), but I could be wrong.

[Guy Incognito]

Can anyone listen to the IPSE webinar?

+1. Anyone have a link please?

[jamesbrown]

+1. Anyone have a link please?

They will send out the link in a day or two.

[Fred Bloggs]

Absolutely, it's worth putting forward your case against MSC in your appeal. I'm just not sure it's worth paying an advisor £hundreds to do it for you. If history is anything to go by, once you engage some advisors, they see you as a cash cow.

But maybe I'm just a cynical bastard who only sees leeches preying on people.

I'm afraid, I think that view is entirely justifiable. Contractor tax issues are the gift that just keeps giving. At the contractor's expense. Only one winner there.