(Don't take this as gospel.)
The review means that the LC will now only apply to loans taken out on, or after, 9 Dec 2010.
Q1) Where does this leave open (protected) years prior to 2010?
A1) Although they will no longer be subject to the LC, they are still under dispute. HMRC has the option to take test cases to a tribunal to get a ruling on whether tax is due. If they were to win a case, they could use Follower Notices to catch everyone who used the same scheme.
Q2) What about closed (unprotected) years prior to 2010?
A2) These are now 100% in the clear.
Q3) What if I've paid APNs for pre-2010 years; will I get the money back?
A3) No. The review has no bearing on APNs. (APNs only ever applied to open years.)
Q4) What if I've already settled closed years ('voluntary restitution') prior to 2010?
A4) If the settlement was reached since March 2016, you should get a refund.
Q5) What about open pre-2010 years which have been settled?
A5) These will remain settled, and there will be no refund.
The review means that the LC will now only apply to loans taken out on, or after, 9 Dec 2010.
Q1) Where does this leave open (protected) years prior to 2010?
A1) Although they will no longer be subject to the LC, they are still under dispute. HMRC has the option to take test cases to a tribunal to get a ruling on whether tax is due. If they were to win a case, they could use Follower Notices to catch everyone who used the same scheme.
Q2) What about closed (unprotected) years prior to 2010?
A2) These are now 100% in the clear.
Q3) What if I've paid APNs for pre-2010 years; will I get the money back?
A3) No. The review has no bearing on APNs. (APNs only ever applied to open years.)
Q4) What if I've already settled closed years ('voluntary restitution') prior to 2010?
A4) If the settlement was reached since March 2016, you should get a refund.
Q5) What about open pre-2010 years which have been settled?
A5) These will remain settled, and there will be no refund.
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