Originally posted by Iter
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By "met the disclosure" I assume you mean that you consider you have disclosed the use, value, name, lender, borrower, of the scheme you used between December 2010 and April 2016 and as such have an argument that these years should be regarded as outside loan charge.
HMRC has indicated to use that "disclosure" via notes in company accounts does not meet the statutory test. We can (and may) challenge that, but for now any such claim will be met with denial by HMRC.
You then say that you may have "new enquiries then reopened". I'm not sure what that means but a new enquiry can be made ONLY within statutory time limits.
An old enquiry that has been closed via agreement, settlement or following Tribunal action, cannot be reopened.
I absolutely understand that the point of your post was to claim that HMRC cannot be trusted in this space. That may be so but the reasons you advance are not correct.
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