Hello.

We're preparing for litigation on the above.

We are expecting a date for a directions hearing at FTT to be set for Q4 this year.

Our own client database is being searched for documents and materials to support an analysis we have already prepared but wish to improve in anticipation of a substantive case being hear perhaps Q1 next year.

I am interested in HMRC actions on this scheme because certainly we have not had closure notices for ALL our clients in this scheme. Showing that HMRC is cherry picking cases is important and building a picture of the state of enquiries (and indeed the consistency of enquiries) is important.

If you used this scheme and are able to help us in building a picture, we would appreciate it.

You will not be obliged to join the litigation or Big Group or to pay a fee of any description.

Clearly if we go to litigation and win, you may benefit. If we go to litigation and lose, you may not.

If you have settled, then you have nothing to lose here.

Please PM or call my office on 0203 468 0000.