BIG GROUP

[RajaStyle]

Count me in

[webberg]

I've been on holiday recently so apologies for the delay in responding.

We will be publishing some thoughts to our BG members this week I think as to our next strategy steps.

Clearly the Rangers case will be important but there are also other moves going on which promise to become critical.

[me206et]

Lutea 03/04

I was with lutea 03 and a few months in 04 but have been out the country since then.
I have just been contacted by the new Trustee/s ventura but cannot get hold of anyone since then.

Anyone else in the same boat.

Is there anyway of working out what it would cost to settle,or wait?

Thanks.

[BrilloPad]

I was with lutea 03 and a few months in 04 but have been out the country since then.
I have just been contacted by the new Trustee/s ventura but cannot get hold of anyone since then.

Anyone else in the same boat.

Is there anyway of working out what it would cost to settle,or wait?

Thanks.

Try a search. You will find that most of the discussion is on the closed BG forums.

[Jarzinhio]

April 2019 charge and the Ranger case

Right conclusion, wrong reason.

The payment to the employee is taxable income.

He/she subsequently makes a trust contribution and gets a loan.

Hi webberg,

just thinking does the Rangers case make the APR 2019 charge sort of irrelevant. So reading a previous article of yours New Contractor Loan Scheme guide goes live :: Contractor UK it says

"However, at Budget 2016, HMRC threatened retrospective action against the former users of disguised remuneration schemes who had so far declined to take up the CLSO.

The department said at the time: “All loans or debts from a disguised remuneration scheme will be taxed as earnings if they haven’t already been fully taxed or repaid on or before 5th April 2019.”

But now it can be argued that they were fully taxed by the employer or we had expected they had been so we can't pay the same tax twice? Then is it a case of HMRC to have to prove that we genuinely thought the company was paying the tax as if we knew they weren't then we are then liable?

[webberg]

I would say that the Rangers case and its conclusions might be limited to situations that are sufficiently similar whereas the 2019 charge is aiming to be a catch all.

I can see situations where one may have precedence over another and equally situations where the question is less obvious.

Sorry - not much clarity but then that is the situation for everybody and HMRC in particular, who created this problem, do not seem inclined to produce any answers.

[EBTContractor]

HMRC not taking my money

I recently asked HMRC to settle a handful of years worth of loans. They kindly sent me a calculation overview of the delta between a couple of APNs + accrued interest, as well as post 2011 years. I was ready to pay.

3 weeks ago they sent me another letter saying "unfortunately HMRC's position regarding settlement of the tax affairs of scheme users is now under review and therefor unable to confirm a final calculation of the additional sums that might be payable and to arrange a settlement with you."

What's this all about?

Has a) Rangers changed the position or is b) HMRC pushing everything out to 2019 when loans will be taxed as income, so whether you pay now or in 2019 no longer matters to them?

[difficulttimes]

CL5??

Did you complete a CL5 form by this or just receive a letter from them?

[DotasScandal]

I recently asked HMRC to settle a handful of years worth of loans. They kindly sent me a calculation overview of the delta between a couple of APNs + accrued interest, as well as post 2011 years. I was ready to pay.

3 weeks ago they sent me another letter saying "unfortunately HMRC's position regarding settlement of the tax affairs of scheme users is now under review and therefor unable to confirm a final calculation of the additional sums that might be payable and to arrange a settlement with you."

What's this all about?

It's not about money, it's about punishment (i.e. torture).
They simply don't want to give closure to anyone.
You are not the only one in this position.

[webberg]

Whilst I cannot agree with the comments above as to HMRC's motives, there are signs that some settlement proposals (not all) are being stalled.

We think that this is because of cases coming before FTT in the next few months, perhaps some implications from Rangers, possible new Budget shortly into the new session of Parliament and perhaps connected with the move work on most schemes being moved to Scotland.

I suggest that if you are in this position, you ask exactly why your case is being stalled. Better to know than to speculate.