Reply to: HMRC amendments to closure notices

[peasant2023]

May I ask who Julia Kermode is - if there's any way she could help me on this then, yes, I'm happy to contact her.

Can she help clarify the <unspecified> bit?

Doubtful, that probably requires a Tax Advisor and/or MP - but she shines a spotlight on matters relating to this topic, in a confidential manner...which makes it harder for things to happen 'behind closed doors'.

[WTFH]

May I ask who Julia Kermode is - if there's any way she could help me on this then, yes, I'm happy to contact her.

https://www.linkedin.com/in/juliaker...alSubdomain=uk

[interestedparty]

HMRC employee advises that Information was received from source about entities using pre-paid cards over an duration.

You need professional assistance with this.
How else can you reach a resolution? Doesn't sound like you've much faith left in HMRC.

If you've worked with a Tax Consultant in the past, they will support you.
If not - then seek a consultation immediately and before taking any further steps.

Contact your MP to request that all of the unspecified bits are clarified.

Would you consider contacting Julia Kermode confidentially?

May I ask who Julia Kermode is - if there's any way she could help me on this then, yes, I'm happy to contact her.

[peasant2023]

It's just me and a HMRC employee (counter avoidance) communicating via email/phone. No tax specialists are involved.

HMRC employee advises that <Unspecified> Information was received from <unspecified> source about <unspecified> entities using <unspecified> pre-paid cards over an <unspecified> duration.

You need professional assistance with this.
How else can you reach a resolution? Doesn't sound like you've much faith left in HMRC.

If you've worked with a Tax Consultant in the past, they will support you.
If not - then seek a consultation immediately and before taking any further steps.

Contact your MP to request that all of the unspecified bits are clarified.

Would you consider contacting Julia Kermode confidentially?

[interestedparty]

Are you working with a Tax Specialist or is this happening "behind closed doors"?

It's just me and a HMRC employee (counter avoidance) communicating via email/phone. No tax specialists are involved.

[SapphireStooge]

From what I can gather, based on a phone conversation with HMRC, is that they will be recalculating the figures based on information they've received (no details given on source) regarding the use of charge cards issued to contractors.

Are you working with a Tax Specialist or is this happening "behind closed doors"?

[interestedparty]

I'm not saying it hasn't happened before, but this is certainly the first time I've heard of them attempting to go back beyond the 4-year window with a scheme.

Hopefully they won't succeed.

I don't know how they intend to do this, but I got the impression they plan to calculate the increased liability arising from the charge card usage and to impose this on me in my individual capacity in addition to the tax already stated on the closure notice. If they can do this then it just reinforces the view that they can make their own rules.

[DealorNoDeal]

Mine was a typical loan scheme using my own LTD than rather an umbrella company. So the personal tax and NICs has been paid on the loans, they are now seeking the employers NICs.

I'm not saying it hasn't happened before, but this is certainly the first time I've heard of them attempting to go back beyond the 4-year window with a scheme.

Hopefully they won't succeed.

[Jumper]

Mine was a typical loan scheme using my own LTD than rather an umbrella company. So the personal tax and NICs has been paid on the loans, they are now seeking the employers NICs.

[DealorNoDeal]

So I closed my LTD over 4yrs ago and HMRC have applied to reinstate the company. Interesting thing now is that the 4yrs has lapsed and the company is still closed so a Reg80 hasn’t yet been issued so waiting to see what action they take. It’s employers NICs they are seeking.

Was your LTD involved in a scheme like this Procorre one?

[Jumper]

So I closed my LTD over 4yrs ago and HMRC have applied to reinstate the company. Interesting thing now is that the 4yrs has lapsed and the company is still closed so a Reg80 hasn’t yet been issued so waiting to see what action they take. It’s employers NICs they are seeking.

[DealorNoDeal]

From what I can gather, based on a phone conversation with HMRC, is that they will be recalculating the figures based on information they've received (no details given on source) regarding the use of charge cards issued to contractors.

Have they said how they are going to assess this? A Reg 80 against the company?

I'm guessing they're investigating a lot of contractors in this scheme. I wonder if they're aware that some companies, like yours, have been dissolved?

[interestedparty]

My understanding is they would need to get the company re-opened before they could raise an assessment (Reg 80). That might be even more difficult to justify now it's gone beyond the normal 4-year enquiry window.

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FWIW, with the CK/Boox investigation, HMRC haven't tried to go back further than 4 years, and nor have they re-opened any companies. If someone had a closed company then they've been let off the hook.

From what I can gather, based on a phone conversation with HMRC, is that they will be recalculating the figures based on information they've received (no details given on source) regarding the use of charge cards issued to contractors.

[DealorNoDeal]

My understanding is they would need to get the company re-opened before they could raise an assessment (Reg 80). That might be even more difficult to justify now it's gone beyond the normal 4-year enquiry window.

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FWIW, with the CK/Boox investigation, HMRC haven't tried to go back further than 4 years, and nor have they re-opened any companies. If someone had a closed company then they've been let off the hook.

[interestedparty]

Companies House confirmed the closure of my limited company in August 2018, so 4.5 years

And the HMRC website say they can issue assessments up to six years after the relevant tax period where corporation tax has been lost as a result of the careless behaviour of the person, or another person acting on their behalf.