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  1. Others will have a view but always best to send...

    Others will have a view but always best to send as little as possible. It might be a fishing exercise. Remember they are short of resources so don't make life easy for them. Reply with the minimum...
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    Many Thanks Webberg. My "check of company tax...

    Many Thanks Webberg. My "check of company tax returns are all under Paragraph 24(1), schedule 18 of the Finanance Act 1998. Sorry, one more question: If for example my year end was 28/09/2010 and I...
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    Protected Years

    For a company loan scheme, do HMRC simply need a "simple check of company tax return....". or do they also need Reg 80s, Sect 8 & sect 9 enquiry notices. I ask because they can't find the Reg80s,...
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    Paying back the loan

    I'm sure that this has been covered before and there will be no simple answer, but any advice on the pros and cons of paying back the loan would be much appreciated. All the costs of (IHT, NI, tax,...
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    Ok, So where is HMRC vulnerable

    Many of you are understandably throwing in the towel, but there are some very obvious areas where HMRC is vulnerable.

    1) Legal
    HMRC and the lawmakers have overturned a long established principle...
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    Is HMRC obsessed with wiping out...

    Is HMRC obsessed with wiping out Baxendale-Walker? They don't seem to like him.
  7. You ask the trustee to pay the cash to the...

    You ask the trustee to pay the cash to the company. It does. Your company has a PAYE/NIC obligation.

    Cheers, I did read this but don't understand why the company has a PAYE/NIC obligation if the...
  8. Such is the nature of public forums that like a...

    Such is the nature of public forums that like a river they eventually meander away from their starting point. I was hoping for a some simple input on what happens if you repay the loan (either via...
  9. Many thanks WHYSOSERIOUS I think this one is...

    Many thanks WHYSOSERIOUS

    I think this one is worth exploring, particularly given that the draft legislation invites taxpayers to repay loans. Let's say the loan is repaid to the trustee with an...
  10. OK let's say you want to unwind your EBT

    In the run up to the 2019 retro tax, if might make sense to unwind an EBT. Let's say you own the company and have taken out £1mill. HMRC says that if you pay the loan back you are home free.
    1) Do...
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    HMRC wins Rangers tax case ruling - BBC News...

    HMRC wins Rangers tax case ruling - BBC News

    https://www.supremecourt.uk/cases/uksc-2016-0073.html
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    I would recommend that you take advice - which...

    I would recommend that you take advice - which shouldn't cost much. If you want to settle then crack on but you also want to guarantee that your have finality. Handing money to HMRC won't necessarily...
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    I'm not so sure, but the devil will be in the...

    I'm not so sure, but the devil will be in the detail. Given that it was a SC anything they say will potentially have weight for other cases. It will depend on how far the SC want to go in defining...
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    The draft decision will be with respective...

    The draft decision will be with respective barristers who will be forwarding corrections to the SC Justices. It is possible that the senior honchos at HMRC will also be in the loop but they will be...
  15. Cheers - well spotted. Perhaps this govt won't...

    Cheers - well spotted. Perhaps this govt won't last long enough to bring them before the house.
  16. Queens speech Etc and 2019 anti-avoidance legislation

    Does anyone have any thoughts on the 2019 anti-avoidance legislation to catch outstanding loans? My understanding is that the legislation didn't make the statue book pre-election and isn't in today's...
  17. HMRC has been known to allow cases to be heard at...

    HMRC has been known to allow cases to be heard at high levels by agreeing to meet costs. It's not usual but it's not that uncommon.

    Fortunately it's not HMRC who "allows a case to be heard". I...
  18. Thanks for that. Somebody clearly thinks it is...

    Thanks for that. Somebody clearly thinks it is worth pursuing this case.
  19. Nobody is obliged by law to continue to appeal a...

    Nobody is obliged by law to continue to appeal a case through the courts, even a liquidator. The liquidator could easily argue that the case has no merit and based on your assessment, even if they...
  20. If it is such a fait accompli why would the...

    If it is such a fait accompli why would the administrators spend so much money defending the case at the SC?
  21. It probably depends on what the ruling says, but...

    It probably depends on what the ruling says, but HMRC's current thinking is that they have you regardless.
  22. Well what an absolutely fascinating couple of...

    Well what an absolutely fascinating couple of days in the Supreme Court. Most likely the last big case for Andrew Thornhill, undoubtedly one of the greatest legal minds for many years. If you can...
  23. https://www.supremecourt.uk/live/court-01.html ...

    https://www.supremecourt.uk/live/court-01.html

    Day two. Fascinating to listen in on all these great minds.
  24. Rangers Tax Case Supreme Court 15 & 16 March

    Here we go again....

    https://www.cchdaily.co.uk/rangers-ebt-big-tax-case-kick-supreme-court

    I think there may be a live feed.
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    Couldn't agree more! When you think about it for...

    Couldn't agree more! When you think about it for a minute the 7 year gifting rule is pretty arbitrary and is more realistic for the very wealthy. I sure don't intend leaving any money to HMRC when I...
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    done

    done
  27. Negligence Claims Against Advisors - an EBT case.

    This is a fairly long judgement but worth reading given that large parts of it relate to EBTs. It was heard in the High Court and is not a Tax Case as such.

    There are various related conclusions...
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    I note a feeling of despondency in many posts. To...

    I note a feeling of despondency in many posts. To me, HMRC latest offering in the budget smacks of desperation. My reading, and I'm no expert, is that they won't have a free ride through the judicial...
  29. There will be a lot of work for the lawyers...

    There will be a lot of work for the lawyers debating what is in Part 7A.
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    I thought that was public sector only.

    I thought that was public sector only.
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    I didn't spot anything, what are you referring to?

    I didn't spot anything, what are you referring to?
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    Today's Budget

    Haven't heard anything yet which troubles me.
  33. Rangers ‘big tax case' rolls on | AccountingWEB...

    Rangers ‘big tax case' rolls on | AccountingWEB

    Possible hearing date of Spring 2017 and I guess a judgement by late summer 2017.
  34. That internal time might be say a team averaging...

    That internal time might be say a team averaging 25 for 12 years at £50k a year each = £15m.

    I really doubt it.
  35. [QUOTE=Iliketax;2221272]No, this was a very...

    [QUOTE=Iliketax;2221272]No, this was a very contrived scheme to get around UK tax rules. It was a way of dressing up a bonus scheme as something else. It had absolutely nothing to do with anything...
  36. HMRC Granted Leave to appeal Rangers Case

    BDO allowed to appeal Rangers tax case to Supreme Court - BBC News

    Hearing in London.
    ...
  37. Supreme Court Decision - Share options and banker's bonuses

    https://www.pumptax.com/wp-content/uploads/2016/03/UBSAG-uksc-2014-0151-judgment.pdf

    Different area to contractor schemes, but looks like an important decision. Appeal allowed.
  38. My experience with HMRC is that when they don't...

    My experience with HMRC is that when they don't have the data, or are out of time, they guess and try it on. If they were less dishonest there is more chance that I might settle. I have now been...
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    As with Hodge, its all about a bunch of second...

    As with Hodge, its all about a bunch of second tier politicians who are out of their depth trying to score points and make headlines and look good on TV. I thought HMRC did OK. Homer looked less...
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    MP Deidre Brock is having a go at grilling HMRC....

    MP Deidre Brock is having a go at grilling HMRC. Her background as a Home and Away actress looks to be helping!
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    Now the turn of the HMRC team. Will see if they...

    Now the turn of the HMRC team. Will see if they are any better.
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    Public Accounts Commitee

    Just listening to the Public Accounts Committee try and grill the Google Tax boys on their affairs. The PAC team are truly dreadful. Meg Hillier - what a disaster. About as effective as a chocolate...
  43. We all have vested interests.

    We all have vested interests.
  44. I guess the next step is a decision on whether...

    I guess the next step is a decision on whether Murray Group gets leave to appeal their case.
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    Claims management group Rebus falls into...

    Claims management group Rebus falls into administration - 04 Feb 2016 - Accountancy Age
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    Coverage in the FT on Rebus suggests that the...

    Coverage in the FT on Rebus suggests that the days of the ambulance chasers are coming to an end.
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    Rebus Goes Under

    I see Rebus has gone into admin. Crowdfunded Rebus in administration - BBC News

    I could never work out why they needed capital and why this should be crowdfunded. I met them and didn't like what...
  48. Agreed, and then add one of these Olympus...

    Agreed, and then add one of these



    Olympus TP-8 Telephone Pick Up Microphone
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    "For periods post March 2011, HMRC is looking to...

    "For periods post March 2011, HMRC is looking to issue discovery assessments or section 28 determinations for 2011/12 before the deadline expires on 5th April 2012".


    Do you mean 5th April 2012,...
  50. You may have had your soup, but the fat lady is...

    You may have had your soup, but the fat lady is yet to sing!
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