Thanks Rob79
My understanding is that because of cases like Rangers (and others) and your IP, HMRC knows this will be difficult. That's why they are taking the ToAA route in their settlement letters. To understand ToAA and recent decisions like Fisher is quite complex. I guess either someone will take proper council view or we will have to wait for cases to reach FTT (and then UTT and then court of Appeal ..... before this is over!) to get clarity
On AML showing profit, they have already made a profit. Now it is more like (past) customer service and they shouldn't need to show profit for this.
My understanding is that because of cases like Rangers (and others) and your IP, HMRC knows this will be difficult. That's why they are taking the ToAA route in their settlement letters. To understand ToAA and recent decisions like Fisher is quite complex. I guess either someone will take proper council view or we will have to wait for cases to reach FTT (and then UTT and then court of Appeal ..... before this is over!) to get clarity
On AML showing profit, they have already made a profit. Now it is more like (past) customer service and they shouldn't need to show profit for this.
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