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AM Limited COP8 HMRC Investigation Letter..

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    AML EBT Judicial Review decision

    So apparently AML have lost the Judical review!

    What's next?

    Comment


      I have been keeping an eye on this thread as I was a contractor who used AML. Has anyone heard anything from either AML or HMRC lately? I asked AML to request a closure notice from HMRC on my behalf back in June but I've not heard a dicky bird since.

      Comment


        Whilst I can't speak for AML I suspect that the closure notice was either resisted and delayed, or has yet to be issued or has been issued and now a case management hearing date is awaited.

        Bear in mind that the FTT is very short of judges and hearings are often scheduled for months away.
        Best Forum Adviser & Forum Personality of the Year 2018.

        (No, me neither).

        Comment


          Originally posted by webberg View Post
          Whilst I can't speak for AML I suspect that the closure notice was either resisted and delayed, or has yet to be issued or has been issued and now a case management hearing date is awaited.

          Bear in mind that the FTT is very short of judges and hearings are often scheduled for months away.
          Thanks. I know some say that no news is good news but I’m not sure that applies to HMRC.

          Comment


            Originally posted by LOL17 View Post
            I have been keeping an eye on this thread as I was a contractor who used AML. Has anyone heard anything from either AML or HMRC lately? I asked AML to request a closure notice from HMRC on my behalf back in June but I've not heard a dicky bird since.
            I also used AML from 2014 - 2016 and like you have been keeping an eye on this thread through the cracks in my fingers! As of now i have not heard anything from AML but would like to contact them, do you have and email/phone number for them?

            Comment


              Originally posted by Worried 72 View Post
              I also used AML from 2014 - 2016 and like you have been keeping an eye on this thread through the cracks in my fingers! As of now i have not heard anything from AML but would like to contact them, do you have and email/phone number for them?
              I would recommend all ex-aml people to look at joining Big Group, we have quite a ex-AML members who benefit by all the help and advice given.
              http://www.dotas-scandal.org LCAG Join Us

              Comment


                Pre 2011 EBT loan pay back

                Has anyone tried paying back pre-2011 AM loan? Is this possible? and if anyone has how did AM redistribute ?

                Comment


                  I take it everyone involved with AML received the emails this morning?

                  Comment


                    Me too

                    Originally posted by LOL17 View Post
                    I take it everyone involved with AML received the emails this morning?
                    Yes. Got mine today.

                    They've been coming out over the past week or so. Looks like in participation date order.

                    MLeggsy

                    Comment


                      Newbie

                      Howdy all,

                      Got the email from AML and Knox house as well 2 separate emails.

                      See below.


                      AML

                      Contractor Loan Legislation - you are affected. Do not delay taking action now.

                      The purpose of this email is to bring to your attention all the options that are available to you concerning the Loan Charge legislation introduced by HMRC, which will take effect from April 2019.

                      As a recipient of a third party loan you will be caught by this punitive legislation and should take remedial action to mitigate your liability without delay. At the time the loans were made, they were within the tax legislation and not taxable. However, the new ‘Loan Charge’ legislation has been made retrospectively and you will be subject to the full force of this legislation when it takes effect in 2019.

                      If you have an ongoing Enquiry with HMRC, you may already be in communication with AML Tax who were appointed to deal with the Enquiries on your behalf. AML Tax is continuing to, and are committed to, working with HMRC and defending the arrangements in the First Tier of the Tax Tribunal where relevant. AML Tax will continue this extensive work in relation to enquiries only. You will have received an email from Knox House Trust, the Trustees of the trust that holds your loan. They have outlined 2 options to mitigate the 2019 Loan Charge; Settlement or Repayment. They cannot offer assistance and have suggested the services of contractor specialist PTS Limited, who can assist with these 2 options. There is no disadvantage to registering your interest in a settlement, however it must be done before 31 May 2018.

                      We would like to draw to your attention that there are further alternative options available. Vanquish Options can provide a mechanism to repay your existing loan which meets the requirements of the Loan Charge legislation and is supported by Tax Counsel opinion. Examples of the financial impact of each option are available. Please take time to review their website and contact Vanquish Options on 0203 740 3876. Taking no action will not avoid the 2019 Loan Charge.

                      Kind regards
                      The AML Team



                      KNOX HOUSE
                      HMRC Contractor Loan Settlement Opportunity - Deadline 31st May 2018

                      As a recipient of a contractor loan whilst working through AML, we are making you aware of new legislation, known as the “Loan Charge”, which will take effect as early as next year and an early Contractor Loan Settlement Opportunity (“CLSO”) that HMRC are offering. We are writing to you as Trustees of the Trust that holds these loans and your action is required.

                      At the time you received your loans, AML had Tax Counsel’s Opinion that the loans were not taxable. When the Disguised Remuneration legislation was introduced in 2010, HMRC only sought to tax relevant payments made after the introduction of the new rules. However, HMRC is now going back and seeking to tax any loans made since 1999, over 10 years before the Disguised Remuneration rules even applied.

                      The 2019 Loan Charge will not apply if the loan is repaid prior to 5 April 2019, or you reach a settlement with HMRC. We will work with you in any way we can to assist you with repayment of the loan. However, there is no other action we, as Trustees, can take to avoid the 2019 Loan Charge applying.

                      You have a personal obligation to provide HMRC with details of your loans. This must be provided to HMRC by 1 October 2019 otherwise penalties will apply.

                      If you take no action then any outstanding loan as at 5 April 2019 will be subject to a tax charge. The legislation treats the outstanding loan as income in the year of charge. For many, this will result in the whole amount becoming chargeable at the higher rate (40%) or the additional rate (45%). In addition, this may result in the loss of the Personal Allowance due to the level of taxable income. Penalties and interest may also be applied if the tax is paid late or you do not disclose the loans to HMRC.

                      The CLSO announced is available to all individuals with outstanding third party loans. The nature of the offer means that your loans will qualify. The CLSO charges tax on the net loan you received, as income in the year of receipt. This means that the actual tax liability will take into account, where available, personal allowances and the basic rate band for each year. In certain circumstances, interest will not be due on the tax. In most cases this will mean that the liability under the CLSO is lower than that under the Loan Charge.

                      Whilst the loan charge is still a little way off, the option to register your interest for the CLSO will close on the 31 May 2018. Registering does not commit you to actually proceeding with a settlement, but not registering in time means that you cannot use the CLSO.

                      If you already have an ongoing Enquiry with HMRC, there is no disadvantage to registering your interest in a settlement. This provides you with time to explore and discuss your options taking into consideration your ongoing enquiries, and to examine whether settlement is appropriate for your circumstances. Settlement information does not have to be provided to HMRC until 30 September 2018.

                      As Trustees it is our obligation to:
                      1. Bring the CLSO to your attention; and
                      2. Highlight the need for you to take action.

                      If you do nothing and your loan remains outstanding, HMRC could at some point in the future make a request under the Exchange of Information rules for the Trustees to disclose the information held regarding your loans. Doing nothing will not avoid the 2019 Loan Charge.

                      We cannot provide direct assistance on tax matters. PTS Limited who are specialised in the provision of settlement services will be able to assist you in considering the full range of options that may be available. Depending on your circumstances, these options may, or may not, include the CLSO.

                      Further detail is provided on the button below together with the option to register your interest in settlement and contact details for PTS Limited.

                      Yours sincerely

                      Knox House Trust Limited
                      Knox House Trust Limited is licensed by the Isle of Man Financial Services Authority and registered in the Isle of Man. Company number 125720C. VAT Registration No. 003 3427 28. Registered Office: Knox House, 16 – 18 Finch Road, Douglas IM1 2PT.

                      Comment

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