HMRC Enquiry letters on Loans from EBT and other schemes

[BrownOwl]

Now that my previous post has been validated - viz Rangers losing major case. Who is the sad act now ? I pity you ... Please seek some major help . You genuinely need it .. No Disrespects .

Do you know this ruling affects the tax liability of Rangers employees?

[Golddustz147]

I am glad you concur

Very logical reply . Best

I suggest that the rather dramatic tone and content above might be worth deeper consideration.

To date, HMRC has won two cases on contractor schemes. One was Boyle - special circumstances, the other is Huitson courtesy of retrospective law.

Until a case is "final", i.e. no further appeal can be made, almost all demands (APN excepted) can be postponed until final decision is made in Court or you agree a position.

I'm aware that recently HMRC has decided to issue closure notices on the arrangements used by a major player in this space and that player has set out what their next steps are. They say (correctly) that if demands are issued, they can be stood over (postponed) until the final liability is agreed. That might be years away.

We await the decision in Murray Group (not on the list to be released in the next week). Other than that, whilst we know of some cases going to Tribunal over the next few months, we are not aware of "HMRC having just won a crucial stage" in any hearing and certainly not one that is going to lead to demands that cannot be resisted.

I'm willing to be corrected if evidence can be produced.

Otherwise, these threads have had enough scare stories and predictions of doom and I think everybody here deserves to treated as adults who are capable of understanding a legal and logical process and should not be exposed to speculation that on the face of it has little or no evidence to support it.

[Golddustz147]

you must be eating your words now?

Why do you care if people pay or not? You come across like a bit of a sad act.

Now that my previous post has been validated - viz Rangers losing major case. Who is the sad act now ? I pity you ... Please seek some major help . You genuinely need it .. No Disrespects .

[TheHat]

That depends on your appetite to risk. And to fight HMRC over 10+ years....

Yep, a perfectly reasonable aspect to consider and judgement to make. However, a totally different position to that taken by the individual (or maybe larger entity) trying to scare others into a particular action with his sad act.

[BrilloPad]

Why do you care if people pay or not? You come across like a bit of a sad act.

That depends on your appetite to risk. And to fight HMRC over 10+ years....

[BrilloPad]

HMRC have just won a crucial stage against other offshore EBT models.

What are you referring to?

[steveb555]

Why do you care if people pay or not? You come across like a bit of a sad act.

or Behavioural Insights perhaps?

[TheHat]

I Received final confirmation last week that HMRC are going to be sending out the final demands and forcing everyone to make payments regardless if they can afford it or not... HMRC have just won a crucial stage against other offshore EBT models. It is just a matter of time of paying up and why delay the inevitable any longer.

Why do you care if people pay or not? You come across like a bit of a sad act.

[webberg]

I Received final confirmation last week that HMRC are going to be sending out the final demands and forcing everyone to make payments regardless if they can afford it or not... HMRC have just won a crucial stage against other offshore EBT models. It is just a matter of time of paying up and why delay the inevitable any longer.

I suggest that the rather dramatic tone and content above might be worth deeper consideration.

To date, HMRC has won two cases on contractor schemes. One was Boyle - special circumstances, the other is Huitson courtesy of retrospective law.

Until a case is "final", i.e. no further appeal can be made, almost all demands (APN excepted) can be postponed until final decision is made in Court or you agree a position.

I'm aware that recently HMRC has decided to issue closure notices on the arrangements used by a major player in this space and that player has set out what their next steps are. They say (correctly) that if demands are issued, they can be stood over (postponed) until the final liability is agreed. That might be years away.

We await the decision in Murray Group (not on the list to be released in the next week). Other than that, whilst we know of some cases going to Tribunal over the next few months, we are not aware of "HMRC having just won a crucial stage" in any hearing and certainly not one that is going to lead to demands that cannot be resisted.

I'm willing to be corrected if evidence can be produced.

Otherwise, these threads have had enough scare stories and predictions of doom and I think everybody here deserves to treated as adults who are capable of understanding a legal and logical process and should not be exposed to speculation that on the face of it has little or no evidence to support it.

[Golddustz147]

P9.5a documents nearly here time is ticking

I Received final confirmation last week that HMRC are going to be sending out the final demands and forcing everyone to make payments regardless if they can afford it or not... HMRC have just won a crucial stage against other offshore EBT models. It is just a matter of time of paying up and why delay the inevitable any longer.