Another Consulting Overseas Victim?

[LisaContractorUmbrella]

And should the HMRC v Murray Group appeal be dismissed, wasn't it HMRC who agreed in this EBT case that loans were not emoluments, which could be in direct conflict of the Boyle Case.

2 out of the 3 judges in the case agreed that the loans were not emoluments for tax purposes - don't think HMRC ever agreed with them as they are taking the case to appeal

[eek]

2 out of the 3 judges in the case agreed that the loans were not emoluments for tax purposes - don't think HMRC ever agreed with them as they took the case to appeal

FTFY as the upper Tribunal has finished and people are just awaiting the decision.

As an aside Boyle didn't appeal so that decision is final.

[wePaid4PortcullisHouse]

Have any of you been able to make any sense of this excerpt from the "Background" in the Boyle case:

"..........
On 26 February 2003 Dr Jacobs held a meeting with inter alios a Brian Garside of
Garside & Co (“Garside”) specialists in this type of investigation who had been
brought in by SSL’s agent, and a Paul Bishopp, managing director of SSL. It was
learned at that meeting that SSL had a master service agreement with SCL, which was
an Isle of Man company, having been transferred there on 9 August 2001.
..............
Credex’ business as a foreign exchange broker was web-based. Its website ceased
to be accessible after the last loan payment was made by SCL on 10 February 2004.
At the meeting on 17 November 2003, to demonstrate to Dr Jacobs that Credex’
website worked, Garside had opened an account with Credex.

An e-mail provided by Garside was found to have been automatically redirected to COL.
..............
"

(1) Why did Garside, who was a specialist "... in this type of investigation ...", provide an email to HMRC that could be used by HMRC as evidence that the "scheme" did not work? Being a specialist in this type of investigation, presumably he would have tested the process a few times to ensure that the system was not flawed in any way and could not be used by HMRC to their advantage.

(2) How does one know that an email has been "... automatically redirected ..." without having access to Credex's software systems?

It seems to me more like co-operation than anything else.

[nickersan]

What now?

What are the options now for anyone that was involved with the Sandfield scheme?

I'm trying to discuss the matter with HMRC who expect about 70% of what I received.

Not getting very far and feel totally out gunned...

[backrubber]

Actinium Management Ltd

Have any contractors who worked through Actinium Management Ltd heard anything from anyone in recent years?

[manoj]

information on how to get information about the loans given by sandfied systems ltd

Can anyone help please - trying to get information on how to and where to get information on loans provided by Sandfield Systems, thx

[canoas]

I just received a HMRC letter from their avoidance support team, the letter states it's in regards to Actinium Dividend Scheme for 1 year and 3 months before I went LTD in 2006/2007. I can't believe this, never received a letter until now June 2022!! I haven't filled in the form to find how much I owe, but come on, 16 years later......have the HMRC got nothing to do! They should've written it off, I mean it's probably been millions of pounds to investigate and probably will end a loss for them. I can't believe my disappointment, anyone has any suggestions? Dreading the amount owed, they will probably backtrack 17 years of interest!

[DealorNoDeal]

I just received a HMRC letter from their avoidance support team, the letter states it's in regards to Actinium Dividend Scheme for 1 year and 3 months before I went LTD in 2006/2007. I can't believe this, never received a letter until now June 2022!! I haven't filled in the form to find how much I owe, but come on, 16 years later......have the HMRC got nothing to do! They should've written it off, I mean it's probably been millions of pounds to investigate and probably will end a loss for them. I can't believe my disappointment, anyone has any suggestions? Dreading the amount owed, they will probably backtrack 17 years of interest!

If this really is the very first correspondence you've had off them, then they are too late to tax you. However, other people who used this scheme did have enquiries opened into their tax returns many years ago, so maybe you've forgotten an earlier letter?

The interest for 2005/6 will be around 58%. Eg. if you owed £10,000 in tax/nics, then the total including interest would be around £15,800.

[DealorNoDeal]

I just received a HMRC letter from their avoidance support team, the letter states it's in regards to Actinium Dividend Scheme for 1 year and 3 months before I went LTD in 2006/2007.

Does the letter say what they are going to do? Sometimes they write to you as a precursor before issuing certain types of notices.

[canoas]

Does the letter say what they are going to do? Sometimes they write to you as a precursor before issuing certain types of notices.

Says "our records show that you were involved with the following avoidance scheme Actinium Dividend for tax year 2006/2007......you may genuinely have no idea that you have been involved in avoidance and there are some umbrella companies that do operate compliant schemes. Fill in on line form and search disguised remuneration setting your tax affairs terms 2020, if you decide to settle under these terms there's an online form to fill in......................................."

Seems quite vague actually!