Edge EBT thread

[ramzanamin]

Be very care ramzanamin. Your response if not professional can go very negatively against all the Edge EBT users and potentially other scheme users as well. Saloes seems on the ball to me. All Edge EBT guys should come together quick. Do you have a deadline by when to respond?

If HMRC will get a weak response they will move forward quickly. Look how they took Boyle to FTT and must have know he did not had good representation. Fragments and non-professional handling on these issues will be bad for all. PM me or write here if you need any help. I am not with Edge but used another scheme

Thanks - am looking for assistance , want to ensure I send a strong response. I have contacted saloes and have been sent material to join which I will. My deadline is by 25/12 so I don't have long any guidance appreciated to meet this deadline

[varunksingh]

Thanks - am looking for assistance , want to ensure I send a strong response. I have contacted saloes and have been sent material to join which I will. My deadline is by 25/12 so I don't have long any guidance appreciated to meet this deadline

Thats very good. I hope more Edge contractors come together quickly and group gets formed.

[DonkeyRhubarb]

Thanks - am looking for assistance , want to ensure I send a strong response. I have contacted saloes and have been sent material to join which I will. My deadline is by 25/12 so I don't have long any guidance appreciated to meet this deadline

Wait to see what Saleos advises.

Worst case, you could just reply with the standard appeal letter. (HMRC are so snowed under they may not even notice)

It's better to say nothing than the wrong thing.

Whatever you do, send it recorded delivery so you have proof of posting.

[DonkeyRhubarb]

Out of interest, does anyone know how many contractors were in the Edge scheme?

If a few hundred join Saleos then you should be in good shape in terms of a fighting fund.

If it costs you a few hundred quid each, that is a very small price to pay. Even £1000 each would be worth it.

I can't emphasise enough the importance of decent representation when you are taking on HMRC.

[TheEdge]

QC representation - value for money

Regarding a fighting fund - if 100 ex-Edge contractors sign up to Saleos thats nearly £100k. In brief for that amount a review of the Edge arrangement is undertaken together with centralised coordination with HMRC. Whilst this is of clear value would the £100k (assuming 100 want to commit) be spent more effectively with an eminent Tax QC from Essex Court or Grays Inn Chambers? The hourly fees of renowned tax barristers such as Malcolm Gommie CBE, QC, David Goldberg QC or Felicity Cullen QC would buy perhaps 50-100 hours of their time. Question is - at a tax tribunal HMRC may wheel out the most capable tax QCs - a lot for a tax consultant such as Saleos to take on (albeit an experienced one)? A tribunal is a one off opportunity after all. Where is money most effectively spent? If anybody agrees then next step would be to engage Inns of Court for EBT knowledgeable barristers who have set up schemes like the Edge/Mapatui/ Tenon/Norla one.

[TheDandy]

Regarding a fighting fund - if 100 ex-Edge contractors sign up to Saleos thats nearly £100k. In brief for that amount a review of the Edge arrangement is undertaken together with centralised coordination with HMRC. Whilst this is of clear value would the £100k (assuming 100 want to commit) be spent more effectively with an eminent Tax QC from Essex Court or Grays Inn Chambers? The hourly fees of renowned tax barristers such as Malcolm Gommie CBE, QC, David Goldberg QC or Felicity Cullen QC would buy perhaps 50-100 hours of their time. Question is - at a tax tribunal HMRC may wheel out the most capable tax QCs - a lot for a tax consultant such as Saleos to take on (albeit an experienced one)? A tribunal is a one off opportunity after all. Where is money most effectively spent? If anybody agrees then next step would be to engage Inns of Court for EBT knowledgeable barristers who have set up schemes like the Edge/Mapatui/ Tenon/Norla one.

And at this stage exactly what would you instruct such eminent barristers to do for your fictitious group? How far do you seriously expect £100K to go. It certainly won't get you to the courthouse steps, which if you are extremely lucky is where you could hope HMRC to settle!

The FTT is not a one-off step, it's the First Tier. Think in terms of 7 figures for the long haul. Maybe put a 2 or a 3 at the start of that number......

[DonkeyRhubarb]

Regarding a fighting fund - if 100 ex-Edge contractors sign up to Saleos thats nearly £100k. In brief for that amount a review of the Edge arrangement is undertaken together with centralised coordination with HMRC. Whilst this is of clear value would the £100k (assuming 100 want to commit) be spent more effectively with an eminent Tax QC from Essex Court or Grays Inn Chambers? The hourly fees of renowned tax barristers such as Malcolm Gommie CBE, QC, David Goldberg QC or Felicity Cullen QC would buy perhaps 50-100 hours of their time. Question is - at a tax tribunal HMRC may wheel out the most capable tax QCs - a lot for a tax consultant such as Saleos to take on (albeit an experienced one)? A tribunal is a one off opportunity after all. Where is money most effectively spent? If anybody agrees then next step would be to engage Inns of Court for EBT knowledgeable barristers who have set up schemes like the Edge/Mapatui/ Tenon/Norla one.

Also check out Pump Court Chambers which specialises in tax.

The scheme promoters will probably have obtained a QC opinion on the scheme before offering it. It would be worth Saleos, or whoever is representing you, trying to get hold of this. It may even be possible to consult with the original QC.

I would hope that Saleos would use a QC for the tribunal (preparing grounds of appeal + actual hearing). If that is not the case then I would have reservations.

[Ron Swanson]

HMRC LSS

Link below provides a quick summary of the HMRC Litigation & Settlement Strategy - as well as providing links to the source materials on the HMRC website

Tax Enquiry Solutions

[varunksingh]

Regarding a fighting fund - if 100 ex-Edge contractors sign up to Saleos thats nearly £100k. In brief for that amount a review of the Edge arrangement is undertaken together with centralised coordination with HMRC. Whilst this is of clear value would the £100k (assuming 100 want to commit) be spent more effectively with an eminent Tax QC from Essex Court or Grays Inn Chambers? The hourly fees of renowned tax barristers such as Malcolm Gommie CBE, QC, David Goldberg QC or Felicity Cullen QC would buy perhaps 50-100 hours of their time. Question is - at a tax tribunal HMRC may wheel out the most capable tax QCs - a lot for a tax consultant such as Saleos to take on (albeit an experienced one)? A tribunal is a one off opportunity after all. Where is money most effectively spent? If anybody agrees then next step would be to engage Inns of Court for EBT knowledgeable barristers who have set up schemes like the Edge/Mapatui/ Tenon/Norla one.

I think at this point you need an accountant with proper knowledge of EBTs. Saleos seems like one of those and others might be better or worst. Later on in the process you will need a QC/good representation at FTT. With a large group costs can be manageable.

Also ask Saleos or someone that for those who wish to settle might agree to just pay back the money to Edge EBT. This MIGHT help ( I am not sure and just thinking out loud). For eg if someone has a £2K bill and wants to pay, if they agree to payback the loan and take the money after paying £2K tax as PAYE than
1) It has been proved that some have paid back the loan and thus additional proof that these are loans.
2) This test case was happy to pay £2K tax anyways so financially they are not worst off.

I am not sure if something like above can workout of not but think all options should be considered.

[malvolio]

I think at this point you need an accountant with proper knowledge of EBTs. Saleos seems like one of those and others might be better or worst. Later on in the process you will need a QC/good representation at FTT. With a large group costs can be manageable.

Also ask Saleos or someone that for those who wish to settle might agree to just pay back the money to Edge EBT. This MIGHT help ( I am not sure and just thinking out loud). For eg if someone has a £2K bill and wants to pay, if they agree to payback the loan and take the money after paying £2K tax as PAYE than
1) It has been proved that some have paid back the loan and thus additional proof that these are loans.
2) This test case was happy to pay £2K tax anyways so financially they are not worst off.

I am not sure if something like above can workout of not but think all options should be considered.

Sigh...