Procorre and HMRC Determinations

[LugaM]

Spoke to accountant who was dealing with my accounts, asked me to email the docs to Procorre and they will draft a reply. They are still saying everything is legal. Also noticed I spite of all this letters Procorre doesn’t seem to appear in HMRC list.

Similarly Procorre provided response and appeal acknowledged and they are not on updated list. Lots of companies on list have disappeared and or left contractors high and dry. Believe lots of correspondence taking place directly between the 2 parties at present.

[eek]

From the poster formally known as webberg

Active cases - Procorre

One of the iterations of the above arrangement saw a sale of 96% of shares in a contractor's PSC to Corre SA. In many instances this was accompanied by a change of registered office to an address that we believe was Procorre in the UK.

It would appear that HMRC issued a number of Reg 80 (PAYE) determinations and section 8 (NIC) decisions between February and late March 2023, seeking tax on the loan charge. Given that this is based on the aggregate outstanding loans over the previous nine years, some of the sums demanded were substantial.

Some of these determinations/decisions were sent to the registered office and not the address of the directors (and former owners) of the PSC. It may also be the case that some of these were either not forwarded by Procorre to the registered tax agent or if sent, were filed with no action by those tax agents.

The result is that Debt Management now has an amount of money to chase in respect of a determination/decision that has not been appealed.

The individual directors and former owners are therefore being pursued for sums that they know nothing about in respect of a PSC they no longer own.

Given that HMRC has the ability to transfer the debt to the directors, we have been forced into making a series of late appeals and postponement applications in the hope that HMRC will accept them.

If you used Procorre please check the PSC's account with HMRC and see if there a 2018/19 tax charge that is showing as due and payable. If so, make an appeal as soon as possible.