Edge EBT thread

[mulberryblue]

Hi all,
After complaining that HMRC had the P11D for the year in question and it was their duty of care to amass all information within theor organization before issuing the APN, they have sent a letter titled "Withdrawl of an accelerated payment notice".
Stating that it was issued in error, no need to take any further action or make any payment in relation to the notice.
Is this the end of it?
There is an attached letter "Notice under Part 4, Chapter 3 of the Finance Act 2014" .. so have they reissued the APN under a new law?

Did you complain in writing or in a phone call?

[convict]

No idea. Go back and ask for a closure notice and see what happens

[mulberryblue]

They are saying that the APN is invalid, not the original DA

But why did they withdraw the APN? My question was it because they hadn't used the P11d to calculate the amount of the APN?

[convict]

They are saying that the APN is invalid, not the original DA

[mulberryblue]

Hi all,
After complaining that HMRC had the P11D for the year in question and it was their duty of care to amass all information within theor organization before issuing the APN, they have sent a letter titled "Withdrawl of an accelerated payment notice".
Stating that it was issued in error, no need to take any further action or make any payment in relation to the notice.
Is this the end of it?
There is an attached letter "Notice under Part 4, Chapter 3 of the Finance Act 2014" .. so have they reissued the APN under a new law?

Can I ask did HMRC issue the APN based on a a fictitious figure they made up eg 4 x income, and state they could not find the relevant P11d on their system?

[demby]

Hi all,
After complaining that HMRC had the P11D for the year in question and it was their duty of care to amass all information within theor organization before issuing the APN, they have sent a letter titled "Withdrawl of an accelerated payment notice".
Stating that it was issued in error, no need to take any further action or make any payment in relation to the notice.
Is this the end of it?
There is an attached letter "Notice under Part 4, Chapter 3 of the Finance Act 2014" .. so have they reissued the APN under a new law?

This is epic news - I've been arguing this ever since the discovery assessments were issued - all falling on deaf ears. Now you say they have agreed that the discovery was invalid.

Is there anyway you can reproduce the letter you have received here? (minus the confidential bits of course) - or at least let us know from where the letter came from and the name of the person who sent it.

Something smacks of double standards here!!!!

[killerbackhand]

APN withdrawn

Hi all,
After complaining that HMRC had the P11D for the year in question and it was their duty of care to amass all information within theor organization before issuing the APN, they have sent a letter titled "Withdrawl of an accelerated payment notice".
Stating that it was issued in error, no need to take any further action or make any payment in relation to the notice.
Is this the end of it?
There is an attached letter "Notice under Part 4, Chapter 3 of the Finance Act 2014" .. so have they reissued the APN under a new law?

[demby]

Been advised by HMRC to open a Judicial Review in order to get a re-assessment on a value they admit is wrong. This is due to me notifying them outside the 90 day limit.

Also received their representation decision letter late due to them sending the letter via a system slower than 2nd class mail. This is apparently the HMRC approved way of sending important life-changing letters.

They don't even care if they arrive or not - once posted apparently it's my f'ing responsibility to make sure it arrives - absolute joke.

Letter arrives with just one week to sort out payment - sent email saying "I now expect deadline to be 15th March unless you tell me IMMEDIATELY". Email read (I have a receipt and they admit it was read) - did I get any reply - did I hell. Get email on deadline day saying they won't move deadline and told that I will have to now appeal against any penalties.

[DotasScandal]

"if you do not comply with this informal request"

Ignore it.
This is simply HMRC's next attempt to terrify you into settlement on their terms.
And yes, they have been sent en-masse.

[jn3]

Has anyone received a letter suggesting settlement post-CLSO and requests for documentation and information:

Snippet (letter dated 3 Feb, received yesterday):

~~~~~~~~~~~~~~~~~~~~~~~~~
"Edge Consulting/Limited/Edge Consulting Limited Employee Benefit Trust

The Contractor Loan Settlement Opportunity ended on 30 June 2015. My records show that you chose not to contact HMRC under the opportunity. However, you can still settle matters by agreement and if now wish to discuss this please call me on 03000 568646 or e mail me using our mailbox address cl.resolution@hmrc.gsi.gov.uk if you prefer.

If you choose not to resolve matters in this way, please read the remainder of this letter and the enclosed schedule. It sets out what I now need to complete the checks of your tax position and to progress matters towards possible litigation.

As you are aware, HMRC has opened an enquiry into your tax return for XXXX. In addition there are also an open appeal against an assessment for XXXX.

HMRC issued an accelerated payment notices on XXXX 2015 for XXXX and XXXX in respect of potential liabilities arising from your participation in this scheme. Any payment(s) you have made in respect of these notices would effectively be a payment on account of tax for years XXXX and XXXX. Please note it would not finalise the matter. There remains an open enquiry for XXXX and an open appeal against an assessment for XXXX, which now need to be concluded. In order to do this I shall now require more documents and information about your personal participation in this arrangement.

Request to produce documents and provide information

Details of what I require to check your tax position for the years XXXX and XXXX are contained in the attached Schedule

Please provide a full response by 28 March 2016.

if you do not comply with this informal request, I will consider taking formal action to progress my enquiries. This may include issuing a formal notice to provide information and produce documents.

Please note that you could become liable to a penalty if you conceal, destroy or otherwise dispose of, or arrange for the concealment, destruction or disposal of, any documents listed below which is likely to be the subject of an information notice.

If you feel that you cannot respond to this request, or to any part of it, for any reason, or that you may need more time, please contact me as soon as possible on 03000 568646. Please also do not hesitate to call me if you have any questions or do not understand any part of this letter.

Whichever method you choose to contact us about this check, you need to quote the case reference XXXXXX and in any other references shown above. If you write you need to use the address shown above. If you send documents you must tell us if you want them returned as we may securely destroy then after 90 days.

Yours sincerely

Ian Henderson
Counter Avoidance Technical Team
"
~~~~~~~~~~~~~~~~~~~~~~~~~