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Churchill Knight & Boox clients being investigated as Managed Service Companies

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    Originally posted by jamesbrown View Post

    Apparently, this page has been removed and is being checked for accuracy - it is probably a misunderstanding, as speculated above.
    Fwiw, it looks like they fixed it.

    https://www.ipse.co.uk/ipse-news/ips...from-hmrc.html

    Comment


      Originally posted by jamesbrown View Post



      Fwiw, it looks like they fixed it.

      https://www.ipse.co.uk/ipse-news/ips...from-hmrc.html
      Well that's a complete rewrite from what was there before.

      And it has points that could be easily answered within it - mainly that HMRC can look at later years but they can't go back beyond 2017/18 and cannot now raise fresh cases for 2017/18,
      merely at clientco for the entertainment

      Comment


        Yes, substantially different. As an aside, it is good practice to not break links and to update stories with an editorial note about what/when/why. Hey ho, at least it was fixed.

        Comment


          The original article

          Click image for larger version

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          Last edited by Superfly; 22 June 2022, 20:11.

          Comment


            My charges are 'stood over'.

            I have had some conflicting information regarding an "independent review by an HMRC officer not previously involved".

            Has anyone requested such a review?

            If you have a review does this then mean your charges are no longer 'stood over'?

            I have heard if you request a review it may result in you being forced to pay up or go to First-tier Tribunal?

            Comment


              Stood over means you are waiting for the results of another case see https://questions-statements.parliam...20is%20decided.

              Over 16,000 of those appeals are 'stood over'. This is where HMRC and the taxpayer have agreed to put the appeal on hold waiting for a decision in a related case. Stood over cases are not actively progressed by the tribunal and can remain on hand for many years while the lead case is decided.
              I would seek advice from whoever is advising you as to whether that's a good thing or not...
              merely at clientco for the entertainment

              Comment


                Originally posted by Guy Incognito View Post
                My charges are 'stood over'.

                I have had some conflicting information regarding an "independent review by an HMRC officer not previously involved".

                Has anyone requested such a review?

                If you have a review does this then mean your charges are no longer 'stood over'?

                I have heard if you request a review it may result in you being forced to pay up or go to First-tier Tribunal?
                if you request a review, then if they confirm their opinion you then have to either pay up or appeal to tribunal.

                There’s no need to request a review unless HMRC offer one

                https://www.gov.uk/hmrc-internal-man...dance/artg2010

                Comment


                  The review is simply another officer will take a look if the first officer has acted within accordance of the legislation (Sorry I paused while laughing).

                  The review is not a chance to get your appeal fattened up with lots of great evidence. The general advice seems to be in favour of not taking a review, this is not to say you should not keep beefing up your appeal, until the lead cases have gone to tribunal (and then maybe not even then).

                  Keep pushing HMRC and keep adding to your own individual appeal, keep giving/finding evidence until you have exhausted everything! don't stop digging and providing evidence. It may just sit in a slightly fatter envelope on a desk somewhere but when the tribunal find CK and Boox guilty your individual case will the next in line, uphill struggle yes but all will not be lost.



                  Comment


                    Originally posted by Guy Incognito View Post
                    My charges are 'stood over'.

                    I have had some conflicting information regarding an "independent review by an HMRC officer not previously involved".

                    Has anyone requested such a review?
                    They’re hardly going to come to a different decision are they. I’m pretty certain this isn’t all just the work of some rogue tax inspector.

                    So unless you’re super keen to get to the tribunal I don’t know why you would.

                    I had heard it mentioned on one of the webinars about it might be a good tactic because it starts the clock running for them. Presumably the thinking would be to force HMRC to complete their ‘fact-finding’ and come to a final decision?

                    Comment


                      Originally posted by Hareforthebear View Post
                      I’m pretty certain this isn’t all just the work of some rogue tax inspector.
                      The rushed them out to hit a deadline. They have done zero work to try and determine if any of these companies are MSCs. They put the wrong alleged MSCP on some of the letters!

                      Comment

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