Originally posted by lowpaidworker
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Edge group litigation lost at FTT
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Scoots still says that Apr 2020 didn't mark the start of a new stock bull market. -
It almost feels like this TAA has become a bit like a scheme. (Backed by QC opinion, no doubt )
Starts off small.
Then there's a bandwagon effect, with others copying it.
Snowballs out of control.
Which usually ends with HMRC going all nuclear.Scoots still says that Apr 2020 didn't mark the start of a new stock bull market.Comment
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TAA
- HMRC's (Tom Moore) counter-argument to TAA is that they claim to have the discretion to decide whether UK companies should have complied with the PAYE regs.
- In the case of schemes, they're deeming that the UK companies didn't have to comply, and therefore scheme users are not entitled to any tax credit.
- They're even giving a free PAYE pass to any UK intermediaries which were part of the scheme!
- The stakes are very high for HMRC now. They'll take this all the way to the Supreme Court if necessary.
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Originally posted by More Lamb View Post- HMRC's (Tom Moore) counter-argument to TAA is that they claim to have the discretion to decide whether UK companies should have complied with the PAYE regs.
- In the case of schemes, they're deeming that the UK companies didn't have to comply, and therefore scheme users are not entitled to any tax credit.
- They're even giving a free PAYE pass to any UK intermediaries which were part of the scheme!
- The stakes are very high for HMRC now. They'll take this all the way to the Supreme Court if necessary.
merely at clientco for the entertainmentComment
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Originally posted by eek View PostTrue but HMRC aren't the ones who need to find money to move to the next stage of appeal - the Edge Group members do...Comment
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TAA ... transfer assets aborad I assume ?
Not sure I get the finer point of the arguement here. Is this all going back on the Rangers case ?
Also stakes high.. does that mean HMRC going down one route that might limit other cases ?
Sorry its a mine field but I guess you need to understand some of the basic principals if your caught up.Comment
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Originally posted by lowpaidworker View PostTAA ... transfer assets aborad I assume ?
Not sure I get the finer point of the arguement here. Is this all going back on the Rangers case ?
Also stakes high.. does that mean HMRC going down one route that might limit other cases ?
Sorry its a mine field but I guess you need to understand some of the basic principals if your caught up.merely at clientco for the entertainmentComment
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Originally posted by eek View PostIt means "The Agency Argument" - I will leave it to others to explain it in more detail if anyone wants to as I'm sure I would get it wrongComment
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Just for information.
HMRC's ToAA argument, already demolished in FTT cases has just suffered another blow in a case called Fisher.Best Forum Adviser & Forum Personality of the Year 2018.
(No, me neither).Comment
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Originally posted by eek View PostIt means "The Agency Argument" - I will leave it to others to explain it in more detail if anyone wants to as I'm sure I would get it wrong
If an agency supplies a worker, and there is any supervision, direction or control, then the engagement is covered by the "agency legislation" and the agency must treat the worker as an employee (PAYE).
The agency legislation doesn't apply if the worker is provided to the agency by a Ltd Co. If the Ltd Co is a PSC then the separate IR35 legislation kicks in instead.Comment
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