AM Limited COP8 HMRC Investigation Letter..

[LisaContractorUmbrella]

As I'm going for my pedant of the month award there are promised to be 43,000 APN's issued, 33,000 to individuals and 10,000 to companies.

The 65,000 figure comes from the number of unresolved cases pending with HMRC/Courts.

The HMRC program is rolling out over 20 months. We might see the first APN's in mid September.

Pedantry accepted

[Monster]

Nice idea but a question;

1. why would HMRC take on your loan?

HMRC I doubt would take on the loan. So you can say that you have a loan out in my name just like a mortgage and when the loan provider wants the money back then you are paying HMRC and the loan Provider. That's not how loans work. So if HMRC are so confident they aren't loans then they should be happy to take the liability. Then the provider will ask for the money back from HMRC as they are now liable for it.

[ireland2013]

Rangers Appeal

BBC News - HMRC bids to appeal Rangers tax case

[jbryce]

BBC News - HMRC bids to appeal Rangers tax case

and why are they appealing? Because Boyle is not sufficient for FNs and unlikely to be enough to prove that EBTs are innefective.

HMRC expected to win, They didn't.

[varunksingh]

BBC News - HMRC bids to appeal Rangers tax case

Will be just gr8 if courts do not accept the appeal

[LisaContractorUmbrella]

Not wishing to rain on anyone's parade but you need to consider that the Ranger's case may not have a massive bearing on your cases. The trusts were set up for the benefit of people who were actually employed by Rangers i.e. there would have been MOO and SDC whereas the schemes that have been mentioned on here appear, on the face of it, to be sham arrangements. I may be wrong but I assume that you received payment via a trust from the scheme provider but you actually worked for a third party? Again, it's only conjecture, but I would guess that a judge would not see enough similarities between the Ranger's case and the schemes mentioned on here to just decide that the precedent set in the ruling quashed HMRC's claims.

[porrker]

Not wishing to rain on anyone's parade but you need to consider that the Ranger's case may not have a massive bearing on your cases. The trusts were set up for the benefit of people who were actually employed by Rangers i.e. there would have been MOO and SDC whereas the schemes that have been mentioned on here appear, on the face of it, to be sham arrangements. I may be wrong but I assume that you received payment via a trust from the scheme provider but you actually worked for a third party? Again, it's only conjecture, but I would guess that a judge would not see enough similarities between the Ranger's case and the schemes mentioned on here to just decide that the precedent set in the ruling quashed HMRC's claims.

The Rangers case has little bearing on HMRC challenge of contractors using EBT Schemes. The Rangers case is centred around a Corporation Tax liability HMRC believes Rangers FC owe and not the loans by the beneficiaries. The vast majority of top flight clubs used EBT's with HMRC blessing. The Rangers arrangement was badly executed with contracts giving payment dates and sums to be paid. A big no no in the setup of an EBT….

[DonkeyRhubarb]

Not wishing to rain on anyone's parade but you need to consider that the Ranger's case may not have a massive bearing on your cases. The trusts were set up for the benefit of people who were actually employed by Rangers i.e. there would have been MOO and SDC whereas the schemes that have been mentioned on here appear, on the face of it, to be sham arrangements. I may be wrong but I assume that you received payment via a trust from the scheme provider but you actually worked for a third party? Again, it's only conjecture, but I would guess that a judge would not see enough similarities between the Ranger's case and the schemes mentioned on here to just decide that the precedent set in the ruling quashed HMRC's claims.

I bet HMRC are very clear on the relevance of the Rangers case.

If they ultimately win, it has a massive bearing.

If they lose, it has no bearing.

[ireland2013]

Settlement Letters

If it has no bearing - if they had won the UTT would it have been mentioned on the settlement letters?

[porrker]

I bet HMRC are very clear on the relevance of the Rangers case.

If they ultimately win, it has a massive bearing.

If they lose, it has no bearing.

Not sure how a Corporation Tax issue around payments into an EBT has relevance to an issue on the loans from an EBT to contractor's but hey ho… Good or Bad dependant on outcome