BN66 get out: Any experts here have a view on this?

[LisaContractorUmbrella]

There has been an important development in the case of a former bn66 DTA scheme member who Warr & Co are representing.

HMRC have issued a Section 8 Notice demanding National Insurance contributions on payments (including NI on Trust payments) deemed to have been made by the “deemed employer” (in this instance the UK company of the scheme promoter) . (Obviously the employer could appeal this notice.)

If HMRC are demanding NI from the employer it is highly suggestive that they are concerned that they cannot collect it from the individual taxpayer who participated in the scheme.

Section 8 notices are issued when it is necessary to make a “ruling” on the employment status of a “worker”.

This appears to be a positive movement in proving that the arguments put forward by Warr & co are correct.”

HMR&C will have issued collection notices (I believe called Regulation 80's) to the individuals who participated in the scheme at the same time as the section 8 notices were issued and I would suggest that it means that the HMR&C are quite confident in their pursuit of the scheme operators