Edge EBT thread

[DotasScandal]

so now HMRC**Ts have won against Rangers .. the judgement based on "common sense" not what was tax law at the time regarding loans..
This is a total stitch up they must've paid off the judges.. this is a fking joke..

You're not alone in thinking so

[edgy about edge]

for F*X sake

so now HMRC**Ts have won against Rangers .. the judgement based on "common sense" not what was tax law at the time regarding loans..

This is a total stitch up they must've paid off the judges.. this is a fking joke..

[webberg]

The better hope is that HMRC, by allowing relief for fees via the CLSO (now closed) has set a precedent, a "legitimate expectation" and as such should permit cooperative taxpayers the same terms.

Well they kept that quiet - if they were allowing relief for expenses why didn't they say so and given us the option to settle under those terms. By not publicising this they have purposely settled with individuals under different terms. I suppose it's the old adage "If you don't ask" - but this is yet another underhand tactic from HMRC**ts

Anyone here settled and claimed expenses - you're about to piss off some who didn't

Don't get the wrong end of the stick here.

The CLSO has tended (not always but usually) to tax the net loans, i.e. after fees.

They have NOT allowed relief for travel, subsistence or any other expense.

The netting of management fees was achieved by taxing what was received. So in theory if the end user client was invoiced £100, then the provider would take say £5, pay you £20 as salary, pay £7 as PAYE tax/NIC and allow a loan of £100 - (5+20) = £75. Effectively giving relief for the fees.

NOT RELIEF FOR ANY OTHER EXPENSE.

[demby]

The better hope is that HMRC, by allowing relief for fees via the CLSO (now closed) has set a precedent, a "legitimate expectation" and as such should permit cooperative taxpayers the same terms.

Well they kept that quiet - if they were allowing relief for expenses why didn't they say so and given us the option to settle under those terms. By not publicising this they have purposely settled with individuals under different terms. I suppose it's the old adage "If you don't ask" - but this is yet another underhand tactic from HMRC**ts

Anyone here settled and claimed expenses - you're about to piss off some who didn't

[webberg]

Paying the APN is NOT settling the position.

An APN is just a payment on account of the final liability that still has to be agreed and paid.

Fees paid to providers.

The rules are that if the loans are regarded as salary (taxable as employment income), then a expense has to be incurred wholly exclusively and necessarily in the performance of the duties.

Almost certainly a fee paid to a provider is not paid necessarily in the performance of the duties. A payment to put yourself in a position to perform the duties, is NOT in the performance of the duties.

If the income is deemed some other form of taxable payment, most likely this falls under the "miscellaneous" income rules. As such any expense has to be directly related to the income in order to be deductible. So is a payment to a provider of what HMRC would call a tax scheme, directly related to a payment from a trust? Probably not.

The better hope is that HMRC, by allowing relief for fees via the CLSO (now closed) has set a precedent, a "legitimate expectation" and as such should permit cooperative taxpayers the same terms.

Otherwise, if the strict law is followed, there are probably not grounds for claiming the fees as an expense.

As to those who received and spent the fees, I have no comment.

[demby]

Charges

Has anyone questioned HMRC about where we stand with the 10% and 12.5% charges made by Edge.
Can they be offset against assessments, for example.

These charges would have been used in some part to pay wages or spent by the greedy directors & trustees - any wages would have been subjected to tax, VAT & duties.

HMRC have therefore benefited from funds we pumped into the economy. In the end nearly every penny returns to HMRC - wages are spent sustaining other jobs and VAT and duty is collected and so the cycle goes on.

If the scheme was a scam (as HMRC are now suggesting) directors/trustees (as individuals, not hiding behind a closed company) should be prosecuted and fined and imprisoned. Punitive fines should be imposed and used to offset demands.

It makes me sick that these people have just washed their hands of the whole affair

[bstar1]

My two Edge APNs came in less than what they should have been.... so paid up

My 2 came exactly as expected then challenged them ...they said they'd get back to me in couple of months....couple of months later....they said they'd get back to me another couple of months.

[EBTContractor]

My two Edge APNs came in less than what they should have been.... so paid up

[IPMAN]

Apn 2010-2011

I queried APN for 2010-11 as it was out by around 125k [only] ...

anyway the query was accepted, but its coming upto 2months now and i'm yet to receive a revised figure.

not a problem as such, but i don't wan interest accruing so probably prefer receiving the updated bill.

[regron]

No!

I was just wondering whether it would be possible to just settle the IHT element (to stop IHT accruing).

For the rest of the tax due, wait for the outcome.

Ah, ok. Who knows with HMRC ! They probably don't even know themselves.