Hoey the ultimate free bottomless refill

[ns1]

This can't leave other groups like Big Group and NTRT with many places left to go.

They are fcuked, totally, but I'm sure the delusion will carry on.

I can already hear the yes but no buts.

[GregRickshaw]

I don't know whether anyone has the stomach or money anymore but I could absolutely see a basis for attacking HMRC for not using "their discretion" but instead using contrived and punitive methods for trying to extract cash from people. The complete "we win or we win or we win" that HMCR pursue and the courts allow discredit the whole idea of tax certainty and the "too good to be true" mantras.

It took years for the various police authorities to be investigated and longer still for the results to be adhered too/published. Someone has to govern this lot the lunatics cannot be in charge of the asylum.

Seriously though this is an intolerable situation and cannot be allowed, it's (the loan charge and subsequent scheme overturns) almost bordering the Post Office scandals.

[dammit chloe]

The article suggests the loan charge is now defunct, does this then mean tax will now be collected at the value it was for each year rather than the combining the loans and taxing them as one years revenue, thereby having a much bigger tax bill.

Either way the whole loan charge seems to be in tatters.

Does this then mean those who paid those vast amounts of 'loan charge' will now be refunded? I think not but though I would ask.

The article also suggests only open enquires, and again I assume not overturned 'yet' schemes they can go after.

I imagine Simon and his barristers thought they had a very good case, some parallels there with the current MSC then.

And finally what are HMRC going to do with all the money they are now going to get?!

I don't know whether anyone has the stomach or money anymore but I could absolutely see a basis for attacking HMRC for not using "their discretion" but instead using contrived and punitive methods for trying to extract cash from people. The complete "we win or we win or we win" that HMCR pursue and the courts allow discredit the whole idea of tax certainty and the "too good to be true" mantras.

[DealorNoDeal]

For years after Dec 2010, it was settle or pay loan charge.

The outcome of the Morse review meant years prior to Dec 2010 were out of scope of the loan charge. Anyone with closed years was totally in the clear but that left a huge number of open years for HMRC still to deal with. Since most schemes involved an offshore (ie. IoM) employer, HMRC can now use the Hoey angle to slap a PAYE liability on the scheme users.

[GregRickshaw]

The article suggests the loan charge is now defunct, does this then mean tax will now be collected at the value it was for each year rather than the combining the loans and taxing them as one years revenue, thereby having a much bigger tax bill.

Either way the whole loan charge seems to be in tatters.

Does this then mean those who paid those vast amounts of 'loan charge' will now be refunded? I think not but though I would ask.

The article also suggests only open enquires, and again I assume not overturned 'yet' schemes they can go after.

I imagine Simon and his barristers thought they had a very good case, some parallels there with the current MSC then.

And finally what are HMRC going to do with all the money they are now going to get?!

[Fred Bloggs]

I reckon it won't be long before a lot of loan scheme users find themselves on the receiving end of a "Hoey".

This can't leave other groups like Big Group and NTRT with many places left to go.

Laughing all the way to the bank? In the case of the ambulance chasers.

[DealorNoDeal]

I reckon it won't be long before a lot of loan scheme users find themselves on the receiving end of a "Hoey".

This can't leave other groups like Big Group and NTRT with many places left to go.

[GregRickshaw]

There will be a few HMRC inspectors rubbing their hands together after the latest decision (final decision)

https://twitter.com/DrOsitaMba/statu...061705/photo/1

Sorry it's Twitter I'm sure a better link will be available soon.

Seems the case has given HMRC carte blanche to collect tax from employees at will.

If your case was opened in 1943 though you're off the hook.