Heads up: anyone with open loan scheme years

[ns1]

Top brass in HMRC have given the green light to use this exceptional discretionary power to specifically target loan schemes.

https://forums.contractoruk.com/hmrc...rate-paye.html

The decision notices are particularly nasty in that there is no right of appeal.

Don't be surprised if you get one for Xmas.

[eek]

only if the scheme had an overseas element..

[DealorNoDeal]

only if the scheme had an overseas element..

Which pretty much covers all of them. I don't know of any that didn't involve IoM.

[eek]

Which pretty much covers all of them. I don't know of any that didn't involve IoM.

Hoey really is a case that keeps on giving to HMRC...

[GregRickshaw]

I am sure I read it was 12 years and even if they are not open, maybe I read that wrong.

Just shows how careful the MSC accused have to be in court.

[DealorNoDeal]

Just shows how careful the MSC accused have to be in court.

Indeed. You guys wouldn't be in the predicament you're now in if CBS hadn't gone to court.

[Chevalier]

I am sure I read it was 12 years and even if they are not open, maybe I read that wrong.

Not just that…. If HMRC are going down the overseas income route there’s some pretty stiff standard penalties (up to 200%) that can apply

[GregRickshaw]

And this all came from the Hoey case?

12 years they can go back even if not open?

What happened to overturn the Loan Charge Morse review can't be the Hoey case overturned all of that surely.

[DealorNoDeal]

And this all came from the Hoey case?

12 years they can go back even if not open?

What happened to overturn the Loan Charge Morse review can't be the Hoey case overturned all of that surely.

No, the 12-year window for offshore is new legislation. It doesn't help HMRC that much with loan schemes because everything since Dec 2010 is already caught by the loan charge.

The Hoey counter-offensive enables HMRC to go after all the pre-Dec 2010 open enquiries.

[GregRickshaw]

No, the 12-year window for offshore is new legislation. It doesn't help HMRC that much with loan schemes because everything since Dec 2010 is already caught by the loan charge.

The Hoey counter-offensive enables HMRC to go after all the pre-Dec 2010 open enquiries.

Ah okay thank you. To be honest I haven't paid enough attention to the Hoey case, I know he was on here asking for crowd funding.

I wonder if HMRC wanted Hoey to appeal and go to court as they knew this would create something they wanted. Again shudders down the spine for those remaining in the MSC and it's subsequent hearings... and come to think of it anyone with a LTD and an accountancy practice after the tribunal... Dear me...