HMRC amendments to closure notices

[Jumper]

Do they not need to issue a separate discovery notice for a LTD and wouldn’t limits apply? How long has your LTD been closed for?

[interestedparty]

Do they not need to issue a separate discovery notice for a LTD and wouldn’t limits apply? How long has your LTD been closed for?

Companies House confirmed the closure of my limited company in August 2018, so 4.5 years

[interestedparty]

Companies House confirmed the closure of my limited company in August 2018, so 4.5 years

And the HMRC website say they can issue assessments up to six years after the relevant tax period where corporation tax has been lost as a result of the careless behaviour of the person, or another person acting on their behalf.

[DealorNoDeal]

My understanding is they would need to get the company re-opened before they could raise an assessment (Reg 80). That might be even more difficult to justify now it's gone beyond the normal 4-year enquiry window.

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FWIW, with the CK/Boox investigation, HMRC haven't tried to go back further than 4 years, and nor have they re-opened any companies. If someone had a closed company then they've been let off the hook.

[interestedparty]

My understanding is they would need to get the company re-opened before they could raise an assessment (Reg 80). That might be even more difficult to justify now it's gone beyond the normal 4-year enquiry window.

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FWIW, with the CK/Boox investigation, HMRC haven't tried to go back further than 4 years, and nor have they re-opened any companies. If someone had a closed company then they've been let off the hook.

From what I can gather, based on a phone conversation with HMRC, is that they will be recalculating the figures based on information they've received (no details given on source) regarding the use of charge cards issued to contractors.

[DealorNoDeal]

From what I can gather, based on a phone conversation with HMRC, is that they will be recalculating the figures based on information they've received (no details given on source) regarding the use of charge cards issued to contractors.

Have they said how they are going to assess this? A Reg 80 against the company?

I'm guessing they're investigating a lot of contractors in this scheme. I wonder if they're aware that some companies, like yours, have been dissolved?

[Jumper]

So I closed my LTD over 4yrs ago and HMRC have applied to reinstate the company. Interesting thing now is that the 4yrs has lapsed and the company is still closed so a Reg80 hasn’t yet been issued so waiting to see what action they take. It’s employers NICs they are seeking.

[DealorNoDeal]

So I closed my LTD over 4yrs ago and HMRC have applied to reinstate the company. Interesting thing now is that the 4yrs has lapsed and the company is still closed so a Reg80 hasn’t yet been issued so waiting to see what action they take. It’s employers NICs they are seeking.

Was your LTD involved in a scheme like this Procorre one?

[Jumper]

Mine was a typical loan scheme using my own LTD than rather an umbrella company. So the personal tax and NICs has been paid on the loans, they are now seeking the employers NICs.

[DealorNoDeal]

Mine was a typical loan scheme using my own LTD than rather an umbrella company. So the personal tax and NICs has been paid on the loans, they are now seeking the employers NICs.

I'm not saying it hasn't happened before, but this is certainly the first time I've heard of them attempting to go back beyond the 4-year window with a scheme.

Hopefully they won't succeed.