Reply to: HMRC enquiries for EBT schemes through SANZAR

[sammyj]

Is this group still actively operating? I'd like to be involved if so. I was with Sanzar in I think 2006-2009.

Sam.

[BrilloPad]

Following on from this post: -

http://forums.contractoruk.com/hmrc-...-1-2-hr-2.html

Have Sanzar been shopping people to HMRC?

[jbryce]

Join Big Group. I'm not sure the Sanzar ptivate forum is doing very much at the moment.

[Glenzo]

You now have PM rights

Thanks !

G

[administrator]

Hiya,

can I also have PM rights and be added to any discussions around Sanzar Solutions. I don't know what I ought to do so would appreciate any advice and information possible. Happy to provide / share copies of the letter if it helps.

Cheers

Glen

You now have PM rights

[Glenzo]

HMRC letter today for 2009-2010 & 2010 - 2011

Hiya,

can I also have PM rights and be added to any discussions around Sanzar Solutions. I don't know what I ought to do so would appreciate any advice and information possible. Happy to provide / share copies of the letter if it helps.

Cheers

Glen

[helpplease12]

please can i join the private forum

There is a private vetted forum for employees or ex-employees of the Sanzar, Garraway, Darwin and IQ Contracts schemes, which were all organised by the same underlying group of people.

If you are interested in joining this forum which is separate from CUK then please ensure you are able to use the Private Message (PM) feature of CUK and send me a PM requesting access. PM privileges can be requested via a post and the Administrator will action this for you when your post is spotted, or you can use the Contact Us link at the bottom of this page to pro-actively contact the Administrator. I will then send you the joining and vetting instructions.

Could I please be given PM privileges? I would like to join the private forum, i was with IQ.

Thanks

[pudding]

For this, I'm sure WTT Consulting (or any other professional you chose, really) can help you. It's not part of the BG mandate, but if you're a member of Big Group you may get a discount.

Thanks DOTAS.

[DotasScandal]

More than haappy to join, as I have reading up on them yesterday. But for now I need to complete this self assessment, so need all the help available here.

For this, I'm sure WTT Consulting (or any other professional you chose, really) can help you. It's not part of the BG mandate, but if you're a member of Big Group you may get a discount.

[pudding]

Join Big Group

More than haappy to join, as I have reading up on them yesterday. But for now I need to complete this self assessment, so need all the help available here.

[jbryce]

Join Big Group

[pudding]

I have received HMRC section 9a letter for self assessment of 12-13. Can some one advice me on whether to reply them with all details or not. I have learned that the Director of the IQ contracts (Old) has set-up a company called CHSlimited.co.uk to help the contractor.

I was advised by them not to provide any information to HMRC as its just a informal request and they can use any information I provide against me in the future.
Not sure how to deal with this.
Can some advice me please.

Thanks,

Can you please share on how this is going for you as I have just been asked for self assessment as I was with IQ in 2013. Any advice, help would be very appreciated.

[meta]

PM Access please

Looking to join a group. Please grant PM access.

Thanks

[webberg]

I was self employed and provided my services to X who sold my services to Y (recruitment agency) who provided services to Z (end client). If u follow the money, invoice was from Y to Z - that was Y's earning. Then invoice was from X to Y and that was X's earning. If HMRC is going to tax me X's earning then they will also charge me on Y's earning.

How can that be difficult to defend provided implemented correctly and money trailed can be followed?

I was not in control of Y markup and what they did with their earning and similar was not in control with what X did with earning. X decided to put money into trust after taking all expenses and profit they wanted. A contractor was unable to control any part of the chain.

Tax experts - jump on and rip my post to pieces.

I'd refer to the response of Mr Iliketax above with which I would generally agree.

The accounting principle of substance over form (FRS 5? or am I showing my lack of cutting edge accounting rules?) is very similar to the Ramsay principle found in many tax cases.

In short, the accountants will ignore interim steps (even if legally papered) if they are convinced that those steps are under the control or influence of the ultimate recipient.

The taxman likewise will try to ignore those steps.

It's perhaps harder for HMRC as they have to rely upon a Court to agree with them, whilst the accountant can probably use the "best of knowledge or belief" test.

However if the accounting is (or should be) that interim steps are ignored and profit is credited to the individual partner because of the rules, then unless there is a tax statute that requires an adjustment, the profit figure cannot be amended for tax purposes.

Trusts come in many flavours. In most PBT situations I've seen, they tend to be "bare" or "Baker" trusts. The main characteristic of such is that the trustee has very limited discretion as to what to do with funds received. The fate of funds received is set at the outset and only in some Armageddon scenarios can that be changed.

For tax purposes, the trust is treated as an extension of the individual and all funds received are treated as individual receipts. (I'm simplifying this, but the general effect is as described).

Thus a partnership profit allocated to a trust in which another partner is the beneficiary, results in that partner being taxable on profits allocated to both.

The key question is the degree to which a partner has control. HMRC will argue that signing up to a pre arranged set of actions is probably enough. I'm not so sure.

So, in response to Mr Strength, I think that the present state of law and Court decisions in this area render the argument advanced nowhere near as strong as might be hoped.

Not to say that there's not mileage there, but it's not the killer argument.

[tails007]

Hi. I have today received s letter from HMRC in relation to my time spent with IQ. Can I please be granted access to this forum?

Thanks