HMRC sent a Tax Avoidance Arrangement Letter

[woody1]

They sight the Stephen hoey vs HMRC Supreme Court case of 8 December 2022

Would you know what my options are??

They say in the letter "Were writing to let you know that were continuing our work to resolve the tax disputes relating to your use of these tax avoidance arrangements"

The Hoey case centred around HMRC's use of s684(7A)(b) ITEPA 2003. The fact that it was lost in the highest court in the land means HMRC are free to carry on using it.

There are other legal challenges in the pipeline (eg. WTT Big Group) but realistically the chances of any of them succeeding are slim to nil.

You might be better off considering settling your liabilities and trying to move on with your life. If you can't pay the bill all in one go, HMRC offer payment plans (also known as "time to pay") to pay by monthly instalments over several years. I've heard of them agreeing to 10 years or more.

[shookshiver]

Does the letter cite s684(7A)(b) ITEPA 2003?

They have been using this quite a lot to clobber pre-Loan Charge years (periods prior to Dec 2010).

They sight the Stephen hoey vs HMRC Supreme Court case of 8 December 2022

Would you know what my options are??

They say in the letter "Were writing to let you know that were continuing our work to resolve the tax disputes relating to your use of these tax avoidance arrangements"

[woody1]

Does the letter cite s684(7A)(b) ITEPA 2003?

They have been using this quite a lot to clobber pre-Loan Charge years (periods prior to Dec 2010).

[courtg9000]

Get on your accountant and TII Insurers now!
Do exactly as they tell you. If they tell you to get other professional advice do it.
you have 45 mins until they all go home - use them wisely!

[shookshiver]

The letter states "This letter is about the tax avoidance arrangements you were involved with during the tax year ended 5 April 2011 or earlier". Well i involved in an EBT 2009/10 and it did not fall within the tax year of the 5th April 2011. Or HMRC fishing for confirmation?? What should i do here as im aware that Stephen Hoey was shot down by the Tribunal but not conclusively thought thats my opinion