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  1. Replies
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    I'm not trying to get in to an argument here but...

    I'm not trying to get in to an argument here but your tax point seems to have changed to a commercial one. As I've said many times, I don't advise contractors. I also know little about bounce back...
  2. Replies
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    I haven't asked them but I'd suggest that it was...

    I haven't asked them but I'd suggest that it was because (1) the evidence was that the dividend was legal and was not employment income when paid, and (2) HMRC might find it put themselves in a...
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    I know your post was not aimed at me but after...

    I know your post was not aimed at me but after reading it, I went back and re-read the case as what you wrote suprised me - my memory is not normally that bad!



    No offence, but what do you mean...
  4. Replies
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    As you've written it, that's silly. If something...

    As you've written it, that's silly. If something is earnings then tweaking the dates of when it is paid won't change that. If you pay a dividend at 2pm on each Friday then the fact that it is paid...
  5. This tells you what is "outstanding" (assuming it...

    This tells you what is "outstanding" (assuming it is in sterling) https://www.contractoruk.com/forums/hmrc-scheme-enquiries

    If you want to find out what a loan is, just click the previous...
  6. If it is the same person, he may well know how...

    If it is the same person, he may well know how some of the schemes were operated: Revenue & Customs v Hyrax Resourcing Ltd & Ors (INCOME TAX/CORPORATION TAX : Anti-avoidance) [2019] UKFTT 175 (TC)...
  7. Yes, it's likely to be treated as income and not...

    Yes, it's likely to be treated as income and not CGT.

    The rate of tax is only relevant if you come back to the UK before the end of the temporary non-resident period (of five years).
  8. No, it would be based on Swiss domestic law.

    No, it would be based on Swiss domestic law.
  9. If someone genuinely transfers property to a...

    If someone genuinely transfers property to a company and suffers the tax consequences of transfering property to a company then the Ramsay principle will not change that. The tax consequences of...
  10. Just sell it then. But how does that help you...

    Just sell it then. But how does that help you extract anything other than £1 in Switzerland.
  11. The Ramsay principle always applies. It is...

    The Ramsay principle always applies. It is basically:

    Step 1: Look at what the law says - what did Parliament intend when it chose those words?

    Step 2: Look at the facts - should an individual...
  12. No. The exiting case law on anti-avoidance is a...

    No. The exiting case law on anti-avoidance is a still very relevant. That has not changed. The GAAR is extra.
  13. The GAAR is targeted at things that are abusive. ...

    The GAAR is targeted at things that are abusive. Here the tax "magic" is not being resident in the UK and not being temporarily non-resident in the UK. It is not selling company A to company B,...
  14. If you pay the stamp duty, report the transaction...

    If you pay the stamp duty, report the transaction to HMRC within 30 days under the property rich company disposal rules (terms and conditions apply) and don't come back to the UK quickly so that you...
  15. You might need to research the CGT consequences a...

    You might need to research the CGT consequences a bit more if it holds property.

    And it would be worth understanding stamp duty too.
  16. I wonder if that would make a difference?

    I wonder if that would make a difference?
  17. Replies
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    The reality is that you won't be able to find out...

    The reality is that you won't be able to find out whether a deduction has already been claimed without involving HMRC.

    But whether or not Edge Consulting has claimed the deduction is not the...
  18. Replies
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    2,630

    Or possibly not. Ozbird will have to think about...

    Or 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...
  19. Replies
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    2,630

    Normally, a DTA a would override domestic...

    Normally, a DTA a would override domestic legislation.



    Awesome. But that is not what most DTAs say.
  20. Replies
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    I don't do settlements but that is presumably...

    I don't do settlements but that is presumably what the settlement agreement would say. If not then the double tax relieving rules would seem to apply (e.g. s554Z5 ITEPA 2003).



    Yes.


    ...
  21. Replies
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    I think someone may have hacked webberg's...

    I think someone may have hacked webberg's account.

    Back to the OP.

    Section 554C(1)(ab)(i) ITEPA 2003 says that a waiver of a loan by a relevant third person creates a relevant step.

    Section...
  22. There is no right of appeal from this decision.

    There is no right of appeal from this decision.
  23. Replies
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    8,008

    Sticky: Let's assume that your growth shares are real...

    Let's assume that your growth shares are real shares (e.g. there really is a company, it really has shares with these characteristic, it really has issued them and you really have acquired them). ...
  24. Replies
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    Lancashire & Ors v Revenue & Customs (INCOME TAX...

    Lancashire & Ors v Revenue & Customs (INCOME TAX - whether the appellants are taxable on sums received under offshore partnership and trust) [2020] UKFTT 407 (TC) (13 October 2020)
  25. Replies
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    No, that is not the case with a gift of property...

    No, that is not the case with a gift of property to your company.
  26. Replies
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    I think it may be more complicated than that. ...

    I think it may be more complicated than that. There would be CGT on you if you gifted the property to your company (subject to your annual exemption) and there would also be SDLT (even if the...
  27. Replies
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    No. That is just not true. There are lot of tax...

    No. That is just not true. There are lot of tax rules that mean that tax of one sort or other is due on loans but that doesn't change it from being a loan (e.g. employee disguised remuneration,...
  28. Sticky: I'd also suggest: 1. Looking at the...

    I'd also suggest:

    1. Looking at the liquidator's statements at Companies House (e.g. the 28 July 2020 says HMRC are owed £1 but no narrative and the unknown amount advanced to clients). Then keep...
  29. Replies
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    I'd also suggest: 1. Looking at the...

    I'd also suggest:

    1. Looking at the liquidator's statements at Companies House (e.g. the 28 July 2020 says HMRC are owed £1 but no narrative and the unknown amount advanced to clients). Then keep...
  30. This sentence is basically a lie. If you buy...

    This sentence is basically a lie. If you buy Tesco shares then they go up in value because Tesco does better. They don't go up in value because your unpaid salary goes to Tesco.

    EBTs are used by...
  31. Replies
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    It looks like Admin's account has been hacked.

    It looks like Admin's account has been hacked.
  32. Replies
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    Thanks but no thanks. I don't work in the...

    Thanks but no thanks. I don't work in the contractor area and Saleos seem congnisant of the issues (but I've never met him or had any engagement with him other than seeing his posts on Twitter and...
  33. Replies
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    Sorry, I didn't see that. I just saw the video...

    Sorry, I didn't see that. I just saw the video on the website.
  34. Replies
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    I didn't know he had been hounded out of here. ...

    I didn't know he had been hounded out of here. If he has though, would Insella have been a reason? Ex-tax inspector offers advice on offshore schemes | Business | The Times
  35. Replies
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    I don't want to get involved with elephants but I...

    I don't want to get involved with elephants but I was wondering about this bit. When I read it, I assume that there was a typo but maybe you think not. How can a non-UK employer who operates PAYE...
  36. Replies
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    Is there a difference between "repayment" of a...

    Is there a difference between "repayment" of a loan and paying interest on a loan?
  37. Replies
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    It would probably be interesting to know what...

    It would probably be interesting to know what Schedule 2 said the "appropriate date" was.
  38. Did you find out about the CGT matching rules?

    Did you find out about the CGT matching rules?
  39. Sticky: Zeeman & Anor v Revenue And Customs [2020] EWHC...

    Zeeman & Anor v Revenue And Customs [2020] EWHC 794 (Admin) (03 April 2020)
  40. Thread: ECHR and IR35

    by Iliketax
    Replies
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    Are you overlooking that PAYE is just a payment...

    Are you overlooking that PAYE is just a payment on account? You can include what you think is the right income for the year and ask for a repayment of any tax already withheld. If you and HMRC can't...
  41. Replies
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    You might want to ask your adviser about example...

    You might want to ask your adviser about example 3 "alphabet soup" here: ERSM60030 - Employment Related Securities Manual - HMRC internal manual - GOV.UK When you do, ask them what the highest...
  42. With regard to Hyrax - "Peak Performance...

    With regard to Hyrax - "Peak Performance Solutions" and "Peak Performance Head Office Solutions Limited" were not a "promoter" in the very technical DOTAS tax definition (s307). But I think the...
  43. Replies
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    A benefit in kind on a P11D normally just means...

    A benefit in kind on a P11D normally just means that no interest has been paid. It does not mean that no interest is charged.



    This is misleading. If some or all of a loan is repaid now it...
  44. A benefit in kind on a P11D normally just means...

    A benefit in kind on a P11D normally just means that no interest has been paid. It does not mean that no interest is charged.



    This is misleading. If some or all of a loan is repaid now it...
  45. I don't know about what many accountants do, but...

    I don't know about what many accountants do, but your original statement was wrong.
  46. Because that is what Parliament said when it...

    Because that is what Parliament said when it enacted legislation in 2000 that (after being re-written and than amended) become section 863 Income Tax (Trading and Other) Income 2005.
  47. Just to be pedantic, that is not right.

    Just to be pedantic, that is not right.
  48. Can you ask Phil for the context? Without the...

    Can you ask Phil for the context?

    Without the context, it's difficult to understand where this comes from. For example, he says "A loan is NOT taxable" and that has no context. A loan can be...
  49. Sticky: So similar to Cartref but even trickier because...

    So similar to Cartref but even trickier because pre-December 2010 loans are no longer within scope of the loan charge?
  50. Did you spot the exemption for employees in the...

    Did you spot the exemption for employees in the regulations? I've no idea what they mean as I know little of IOM law.
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