We are waiting on HMRC to file a case in response to our appeal to FTT on the AVENUE structure.
We expect that to be done in August following their application for a 90 day delay.
Once done, we will expect to be at a Directions hearing within 3 to 5 months and a substantive hearing after that.
Our view is that HMRC has jumped the gun here and to date only one of our Avenue clients has the closure notice. We expect that HMRC will be required by the Tribunal to bring all such clients to the same point before the substantive hearing.
We are working to bring our client base to that position in advance of the expected hearings.
We are aware that this structure was a later iteration of the Penfolds/Hamilton family. We were told some years ago that those schemes and perhaps later family members were scheduled for a FTT. We are unaware of whether those Tribunal appearances remain on course for a hearing or not.
AS far as we know however, the actions we are taking on Avenue are the first of their kind.
We have significant data but we can never have enough.
If you have information that you think might be useful and you are willing to share it (we will be entirely confidential) we would appreciate anything that can supplement what we have.
You will not be part of the litigation, not be required to join Big Group and will incur no fee.
Clearly, if we take a litigation and win, you may benefit. If we take a litigation and lose, you may not.
If you have settled already, then you have nothing to lose in sharing data.
Please PM or call the office on 0203 468 0000.
Thank you.
