BIG GROUP

[webberg]

1) lets setup the sheet on google docs and allow others to comment and see

2) I can do the website. Host it in cloud - azure. Will do my work for free - only charge the hosting cost. (If anyone else wants to do it welcome)

3) do we need to form an association or something?

4) my biggest concern is that to defend the scheme, we will need details and documentation on how the schemes were implemented. Don't know how we can get that with promoters gone (for me luckily promoter is around and doing it)

5) don't we need a more concrete action plan and what the benefits would be? What the 4 staffs would do ( I would have thought a project co ordinator - prince certified - like my wife would be enough for office work instead of 4 - might be wrong without a more detailed plan)

2. Thank you.
3. Yes - probably an informal group bound by a constitution
4. Agreed. Most plans have a common theme and can be backsolved. Enough people coming together and sharing data should give the data required. If not, we'll ask HMRC - I'm serious - as they can be obliged to help.
5. yes. See later.

[webberg]

Thanks very much Webberg! Good luck with the football! Do you need anything else other than our real names? Maybe some kind of template? Name, address etc?

I'll circulate the joining criteria in due course.

[jrock]

2 actions groups?

i think it's great that joint action is starting to develop.

My question is should I join this group if my promoter is already supporting me via a judicial review?

Can representation on my APN appeal be brought forward by 2 parties?

[webberg]

One hopes Webberg you are a Spurs fan and a Saint

I'm a Saints fan, man and boy.

I think we're safe from relegation this year and that's always what we look for first.

A draw with Spurs felt like a loss though and the run in is not good. Three teams facing relegation and scraping for their lives and Man City away last game. Looks like Europe might have to wait another before being graced with our presence.

[carling]

i think it's great that joint action is starting to develop.

My question is should I join this group if my promoter is already supporting me via a judicial review?

Can representation on my APN appeal be brought forward by 2 parties?

I'm in the same boat here. Our promoter is already commited (and on the way) to FTT, plus already organising JR activities.
How would this fit in with what is being proposed here ? If this takes off, surely working in conjunction with the fighing promoters would help the cause.
I'd be interested in chipping in the amounts mentioned either way, just to help out people who's promoter have let them down and of course causing maximum aggro for Hector.

[webberg]

I have no skin in this, but you might want to think about how the results for one group change the dynamics for the others.

To keep the numbers simple. Let's say you get an equal number of people for two separate schemes. They all pay monthly and plan to pay £200,000 per year over four years. Let's say one of these is to do with EBTs. Just as the case goes to the FTT after two years and cost 50% of the expected total (say £400,000 of costs out of £800,000 expected for both schemes). So the first two years' money effectively spent on the EBT scheme. As luck would have it, at the same time the Supreme Court hears the appeal of the Court of Sessions on Rangers and says Rangers loses. The FTT says, sorry, but you lose too because the Supreme Court is boss. All the EBT people then leave the group and stop paying.

So the remaining 50% then have to fund 100% of the second case.

So those who are in the EBT group pay £200,000 of their £400,000 costs and those in the second group have to pay £600,000 to get their case heard. That doesn't seem fair.

Now in real life there may be synergies, not all the money will be spent on the first case, you are planning four separate schemes, etc. But unless you do something to address it, it still goes back to those that remain effectively pay more than those that leave early.

Valid points.

The plan I have in mind is to operate at a higher level and seek common threads and elements in a number of schemes. There are perhaps 3 or 4 scheme types operating that I'm aware of:

1. Engagement contracts via an offshore intermediary with funds being moved back to the UK via a trust.
2. The use of loans from a trust (on or offshore)
3. Dual contracts
4. Share/option based schemes

The latter two tend to be non DOTAS.

Common themes are:

Movement of funds
Use of funds (option purchase)
Agency/intermediary rules
ITEPA rules

The need is to find and develop and argue that a combination of facts and law leads to a different result than that HMRC is pushing.

That may require contacting and borrowing from existing groups, contributing a fresh perspective to those groups and sharing the results achieved.

I'll try to capture all this.

[webberg]

i think it's great that joint action is starting to develop.

My question is should I join this group if my promoter is already supporting me via a judicial review?

Can representation on my APN appeal be brought forward by 2 parties?

The Judicial review is against the APN. It has absolutely NO bearing on the settlement or litigation for the agreement of the final position.

The group here will NOT be in place in time to take action on an APN.

The group here is also NOT seeking JR challenges on APN, unless an argument of general application is developed.

[LEC]

Count me in

[jrock]

The Judicial review is against the APN. It has absolutely NO bearing on the settlement or litigation for the agreement of the final position.

The group here will NOT be in place in time to take action on an APN.

The group here is also NOT seeking JR challenges on APN, unless an argument of general application is developed.

Thanks for clarifying.

What is therefore required to join this group at this stage? A commitment to pay £50 (a reasonable initial fee I must add). Will there be additional costs going forward?

Look forward to seeing the required criteria, and put my name forward.

[DotasScandal]

What is therefore required to join this group at this stage? A commitment to pay £50 (a reasonable initial fee I must add). Will there be additional costs going forward?

Please refer to the first post of the thread, it's quite clearly explained.
The 50 quid is seed money to kick start the group. Future costs will depend on how many will be willing to join.