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Montpelier DTA scheme bulletin

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    Originally posted by webberg View Post
    I would say that we have not looked at it because our BG excludes the arrangement and although we had some ideas about "what next", none of our clients wanted to fund the research and inevitable battle with HMRC and therefore we did not proceed.

    From what we see however, the position of many here is that a withdrawal of the claim that Article (3)(2) applies, leaves the income open to assessment and HMRC will finalise that assessment and collect the tax UNLESS there is a route to continue the debate.

    Therefore, doing nothing does NOT delay the inevitable.

    Doing nothing means pay the tax.

    When that tax is due is probably a function of how efficient DMB are.

    Therefore to delay the inevitable, you need to raise new grounds for not paying tax on that income. I touched on some problems with that earlier and say again, that we have not got any fully developed ideas on this.
    The montpelier approach is to delay the inevitable. By endless legal actions that have NO chance of success.

    Comment


      Originally posted by PokemonStay View Post
      The montpelier approach is to delay the inevitable. By endless legal actions that have NO chance of success.
      Ah - sorry - my bad.

      Obviously I can't comment on Montpelier.
      Best Forum Adviser & Forum Personality of the Year 2018.

      (No, me neither).

      Comment


        Originally posted by webberg View Post
        Ah - sorry - my bad.

        Obviously I can't comment on Montpelier.
        Neither does Montpelier. at least since BOK stopped posting here. So about 8 years.

        However WG still reads this thread. Hi WG

        Comment


          Originally posted by PokemonStay View Post
          The montpelier approach was to delay the inevitable. By endless legal actions that had NO chance of success.
          ftfy
          merely at clientco for the entertainment

          Comment


            Utter folly

            Anyone who doesn't take Corrective Action, on the basis of the deluded crap coming out of Montpelier, seriously wants their head testing. (Ditto for people who are stupid enough to repay 10% of the loans for the loan scheme.)

            Take this path and you are almost certainly going to wind up with a 50% penalty.

            And don't come back here crying when it happens.

            WG has been billing people hundreds of pounds, in some cases thousands, for crappy Letters of Representation. Imagine the bill you'll get from him if you join his Judicial Review circus.
            Scoots still says that Apr 2020 didn't mark the start of a new stock bull market.

            Comment


              Originally posted by DealorNoDeal View Post
              Anyone who doesn't take Corrective Action, on the basis of the deluded crap coming out of Montpelier, seriously wants their head testing. (Ditto for people who are stupid enough to repay 10% of the loans for the loan scheme.)

              Take this path and you are almost certainly going to wind up with a 50% penalty.

              And don't come back here crying when it happens.

              WG has been billing people hundreds of pounds, in some cases thousands, for crappy Letters of Representation. Imagine the bill you'll get from him if you join his Judicial Review circus.
              I disagree. Your analysis is too mild. One person has asked for their 10% back. They did not get it.

              I would like to see what WG has to say about this.

              To be fair to WG, it was hard to see retrospective legislation coming. However, since that was lost, so is the whole case.

              Comment


                Originally posted by PokemonStay View Post
                One person has asked for their 10% back. They did not get it.
                I doubt they'll ever see a penny of it ever again. It's all being pissed away on legal wild goose chases.
                Scoots still says that Apr 2020 didn't mark the start of a new stock bull market.

                Comment


                  Originally posted by PokemonStay View Post
                  I disagree. Your analysis is too mild. One person has asked for their 10% back. They did not get it.

                  I would like to see what WG has to say about this.

                  To be fair to WG, it was hard to see retrospective legislation coming. However, since that was lost, so is the whole case.
                  Gitface was giving it large (as his not inconsiderable fat belly, no less) that they had 'others' lined up behind Huitson to take to the FTT seeing as the FTT doesnt set a precedent, after Gitface and his crew blew the late appeal.

                  So where are they gitface? You havent submitted one of these others, have you? Oh and what exactly did you advise Huitson to do again when you blew the late appeal?

                  Comment


                    Email From Montpelier

                    Has anyone else had this or similar email from Montpelier:

                    "Upon checking our records, I note that you have not advised if a response has been received to the letters of representation submitted to HMRC in respect of the FN's and APN's.

                    We are currently looking to add interested parties into the JR and I should be grateful if you would confirm which of the following is relevant to you:

                    1. Letters of representation submitted but no response received as yet from HMRC.

                    2. You have fully settled this matter with HMRC.

                    3. You have paid the APN's but not completed the corrective action forms."

                    I'm a number 2 - but am now extremely wary of discussing ANYTHING with Montpelier following their threat and subsequent attempt to charge for the letters of representation. In fact it was the potential for future potentially unlimited charges from Montpelier which prompted me to throw in the towel and settle with HMRC - so I never used their letter of representation anyway. I don't know whether to reply and tell them I've settled or just ignore them. Any thoughts anyone?

                    Comment


                      Originally posted by justadadnow View Post
                      Has anyone else had this or similar email from Montpelier:

                      "Upon checking our records, I note that you have not advised if a response has been received to the letters of representation submitted to HMRC in respect of the FN's and APN's.

                      We are currently looking to add interested parties into the JR and I should be grateful if you would confirm which of the following is relevant to you:

                      1. Letters of representation submitted but no response received as yet from HMRC.

                      2. You have fully settled this matter with HMRC.

                      3. You have paid the APN's but not completed the corrective action forms."

                      I'm a number 2 - but am now extremely wary of discussing ANYTHING with Montpelier following their threat and subsequent attempt to charge for the letters of representation. In fact it was the potential for future potentially unlimited charges from Montpelier which prompted me to throw in the towel and settle with HMRC - so I never used their letter of representation anyway. I don't know whether to reply and tell them I've settled or just ignore them. Any thoughts anyone?
                      Just ignore the useless bunch of twats. I heard they charged one person 3 grand for their piece of toilet paper LOR.

                      Comment

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