- Visitors can check out the Forum FAQ by clicking this link. You have to register before you can post: click the REGISTER link above to proceed. To start viewing messages, select the forum that you want to visit from the selection below. View our Forum Privacy Policy.
- Want to receive the latest contracting news and advice straight to your inbox? Sign up to the ContractorUK newsletter here. Every sign up will also be entered into a draw to WIN £100 Amazon vouchers!
Loans write off and APNs
Collapse
X
-
-
They won't let me settle. They sent me a letter saying that I could settle but by the time it reached me her in Oz the deadline had already passed. I emailed them and they said that I cannot now settle. I don't know what else to do. I am so sick of this hanging over me and the possibility that the trust could sell the loans and someone come after me for the loan amount. After the offer to settle expired I emailed them and made an offer to settle for an amount of money and asked them if I could even settle the closed year but they just wrote back to say that I should do my tax return and pay the loan charge. I had already done my tax return and the loan charge doesn't apply as its pre 2010. If I have to speak to these guys I am not even sure they are empowered to have these negotiations about offsetting the APN and closing the open enquiry. Its such a mess.Comment
-
Originally posted by Iliketax View PostAwesome. But that is not what most DTAs say.
14.2 Notwithstanding the provisions of paragraph 1 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable *only* in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending *in the fiscal year or year of income* of that other State; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not deductible in determining taxable profits of a permanent establishment which the employer has in the other State.
Possibly "awesome" for Ozbird then?Comment
-
Originally posted by Ozbird View PostThey won't let me settle. They sent me a letter saying that I could settle but by the time it reached me her in Oz the deadline had already passed. I emailed them and they said that I cannot now settle. I don't know what else to do. I am so sick of this hanging over me and the possibility that the trust could sell the loans and someone come after me for the loan amount. After the offer to settle expired I emailed them and made an offer to settle for an amount of money and asked them if I could even settle the closed year but they just wrote back to say that I should do my tax return and pay the loan charge. I had already done my tax return and the loan charge doesn't apply as its pre 2010. If I have to speak to these guys I am not even sure they are empowered to have these negotiations about offsetting the APN and closing the open enquiry. Its such a mess.
If you want to settle the open enquiry, you need to find someone who can deal with pre-2010 loan years.
I would suggest contacting the team who opened the original enquiry but they may not still be around.
Maybe someone else here can point you in the right direction?Scoots still says that Apr 2020 didn't mark the start of a new stock bull market.Comment
-
HMRC are set to detail the new settlement opportunity for pre-2010 years this Autumn.STRENGTH - "A river cuts through rock not because of its power, but its persistence"Comment
-
There is an active group in Australia which is looking at all aspects of the situation.
Happy to effect an introduction if you want to PM me.Best Forum Adviser & Forum Personality of the Year 2018.
(No, me neither).Comment
-
Originally posted by regron View PostHMRC are set to detail the new settlement opportunity for pre-2010 years this Autumn.
1. DR loans not subject to the Loan Charge can be settled based on the August 2020 settlement terms (link provided in the link below).
2. Settlement terms for DR loans which are subject to the Loan Charge, will be published later this year (link below).
Disguised remuneration: settling your tax affairs - GOV.UKSTRENGTH - "A river cuts through rock not because of its power, but its persistence"Comment
-
Originally posted by GoneSurfing View PostPossibly "awesome" for Ozbird then?
For example, the employer may have already claimed a deduction or the waiver will trigger a deduction (s1292(6A) CTA 2009).Comment
-
Originally posted by Iliketax View PostOr possibly not. Ozbird will have to think about the "(c)" bit and that will be a question of fact.
For example, the employer may have already claimed a deduction or the waiver will trigger a deduction (s1292(6A) CTA 2009).
Also, tax in Oz would probably be more tbh because I am earning money from work here. I don't mind not getting my APN back as long as it offsets the amount of tax I would owe. If I had settled I would have paid way more because of all the interest.Comment
-
Originally posted by Ozbird View PostI don't mind not getting my APN back as long as it offsets the amount of tax I would owe. If I had settled I would have paid way more because of all the interest.
I assume you are aware that no additional interest will have accrued since you paid the APN.Scoots still says that Apr 2020 didn't mark the start of a new stock bull market.Comment
- Home
- News & Features
- First Timers
- IR35 / S660 / BN66
- Employee Benefit Trusts
- Agency Workers Regulations
- MSC Legislation
- Limited Companies
- Dividends
- Umbrella Company
- VAT / Flat Rate VAT
- Job News & Guides
- Money News & Guides
- Guide to Contracts
- Successful Contracting
- Contracting Overseas
- Contractor Calculators
- MVL
- Contractor Expenses
Advertisers
Contractor Services
CUK News
- Streamline Your Retirement with iSIPP: A Solution for Contractor Pensions Sep 1 09:13
- Making the most of pension lump sums: overview for contractors Sep 1 08:36
- Umbrella company tribunal cases are opening up; are your wages subject to unlawful deductions, too? Aug 31 08:38
- Contractors, relabelling 'labour' as 'services' to appear 'fully contracted out' won't dupe IR35 inspectors Aug 31 08:30
- How often does HMRC check tax returns? Aug 30 08:27
- Work-life balance as an IT contractor: 5 top tips from a tech recruiter Aug 30 08:20
- Autumn Statement 2023 tipped to prioritise mental health, in a boost for UK workplaces Aug 29 08:33
- Final reminder for contractors to respond to the umbrella consultation (closing today) Aug 29 08:09
- Top 5 most in demand cyber security contract roles Aug 25 08:38
- Changes to the right to request flexible working are incoming, but how will contractors be affected? Aug 24 08:25
Comment