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I am aware of much adverse criticism here and other social media recently, usually based on inaccurate assumptions and/or driven by unknown motivations.

Quite why WTT Big Group is expected to...

You are correct that it's not my money and without a mandate from my clients, I cannot commit.

I have no issues with the lawyers.

Some of the thoughts expressed above we have discussed with...

If it's a check on a company return, it should say section 12 TMA (from memory - I'm not near my text books).

If it does, then there is an open enquiry.

Reg 80 is a PAYE assessment.

Section...

To be fair, where we advised Felicitas of our involvement in an individual's situation, only one or two SDs.

Where we have taken on clients after the last update of authorities to Felicitas, they...

I suggest you ask Edge and they will share their indemnity with you.

To be very clear.

WTT is quoted in the article tagged but the comment/quote above is NOT one that we made.

For the record, we have no information as to Mr Emblin's past or present situation and...

I note the posts (#287/291) from eek above. I confess I was unaware of that fact but thank the mods for their diligence and action.

WTT has a substantial group of clients who are involved in this....

That is dangerous thinking.

If it is dangerous thinking powered by knowledge, professional expertise or personal experience, then I think you owe it to those reading these threads to explain your...

Disguised remuneration settlement terms 2020 - GOV.UK

Lots of new rules to get heads around here.

Interesting (and possibly unlawful) twist here is that if the loan charge is paid AND the...

Revenue & Customs v White Collar Financial Ltd (DOTAS - Application for order that certain arrangements are notifiable) [2020] UKFTT 459 (TC) (16 March 2020)

HMRC applied to the Tribunal for a...

I'm afraid they are not.

Not on paper or otherwise.

Take heed of the above and if you get a demand for the loan go and get some advice.

There are some points above that I have some thoughts on.

First, regardless of history, real or imaging connections between original promoters and present active parties, what you think a Court...

No - and I'm not expecting to given the fact that the rules were not around pre 2013.

UK Regulation of loans exists in the main to protect the borrower.

Therefore the lender has to consider whether the loan will be repaid, affordability, credit worthiness of the borrower, use of...

YOU - not somebody else - YOU need to take steps to protect yourself.

That might be appointing and paying a professional, it might be reading up and using online resources to defend yourself.
...

I've previously written here about some of the bigger umbrellas to whom we sent the same data and received different "net" answers.

The creative use of expenses and application of "emergency"...

Yep - agreed.

So the tax deduction is between £60 and £100 a week less than it might be.

That might be accounted for by expenses - but very doubtful.

There is no tax code via PAYE that gives...

Gross pay is £1,506.

PA - assuming not used elsewhere - is £12,500 a year or around £240 a week.

Taxable pay therefore £1,266.

Basic Rate Tax is £253.60.

Not a million miles away?

What is the interval?

Weekly, fortnightly, monthly?

Clearly you have seen more "implication", than I wrote or intended.

If others have also spotted such implication then let me be clear.

Yes, an individual SD has to be dealt with individually.
...

Pretty sure that Graham is not allowed to.

With respect and without knowing your skill/experience set in this space, we have professional advice that beyond the initial individual by individual response to SDs, then a GLO offers a route...

We offer a free 30 minute initial call.

Contact our main number and one of my colleagues will arrange a conversation.

Ask for a date/time with Graham

Not quite correct.

Have a look at Group Litigation Orders.

Advantage of a group is basically cost sharing.

MERCY GLOBAL CONSULT LTD. - Officers (free information from Companies House)

Lots of activity in the Directors' seats with a fair number of short term placements.

Not that such movement should...

They do claim affiliate status with Apsco so it might be worth a call to them?

The letter is a template that HMRC appear to have issued thousands of.

It may be that the umbrella used did NOT run any form of tax avoidance scheme. Certainly we have seen examples of letters...

You are straying off topic here but I'll go along with it one time.

Your process description is correct aside from the "throw in a CCJ" point. That is not inevitable and with proper management...

Well bearing in mind that there are at least three litigations under way and many more waiting for dates in Tribunal, including ours, you could do worse than explore what those groups are doing.

Correct that an APN is difficult to challenge - there have been many cases in the Courts and aside from HMRC being told to follow their own rules, none have made much difference.

A GAAR pooling...

Where the LC data is disclosed AND the charge paid before or on 30th September, no interest will be charged even though the payment was strictly due 31 January 2020.

GAAR applies only from July 2013.

Yes.

The pooling notice gives you the chance to take action to "correct" your reported position.

If you do not then chances are you will get a counter action notice which will arrive with an...

I have no idea but I suspect HMRC will see the schemes being subject to loan charge AND GAAR.

Don't forget, the loan charge is NOT settlement. Even if paid, it is still necessary to agree the...

You may still get a letter but I think you should have no worries over this as you have settled.

A general advisory.

HMRC has begun issuing GAAR Pooling Notices in respect of arrangements using a version of "remuneration trusts".

Without getting too detailed, HMRC is able to take a set of...

For what this is worth.

A settlement agreement with HMRC usually relates to the tax and interest that falls due on payments made to you and which HMRC considers amount to employment income.

It...

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.

No. If there is no tax in dispute, then ergo, no APN.

There is a process to adjust an APN to NIL (and repay anything paid) but not really a process to "withdraw" an APN.

Rather if the...

Quite an interesting question.

HMRC's position appears to be that a loan write off creates an income tax charge as well as perhaps an IHT charge.

They are not clear why an income tax charge...

Unless you have that advice - in writing - directly from Counsel to you, considering your circumstances, that view is of very limited use.

You should ask to see that advice and the questions that...

Go and get some advice because a lot of comments above are guesses or misleading or both.

HMRC will open an enquiry into a YEAR (never limited to just one aspect within that year) based either on...

I think not.

Lenders cannot "opt out" of something they were never "in".

If a loan is made within the terms of the numerous laws requiring T&Cs to be met, then repayment demands would be also...

There seem to be a fair few posts around on the above.

This may help.

When agreeing a settlement with HMRC, you are presented with a choice to be made on the loans.

A. If you wish to have...

I suggest that investing in a phone call to AML might be worth while, rather than ask anonymous posters here who probaly don't know?

You might also want to check out the CVs of the people at PTS.

Independent adviser is the way to go.

(But I would say that wouldn't I?)

Revenue & Customs v Opus Bestpay Ltd (DOTAS - Application for order that certain arrangements are notifiable) [2020] UKFTT 408 (TC) (18 August 2020)

Para 62 is a one line summary of the decision...

It was a decent enough attempt and I felt in particular for the young lady who lost her father and the guy who has yet to tell his wife and family of his predicament.

They had more integrity about...

There are now quite a few threads running on the above and this is an attempt to pull them together.

I've also mentioned what we are others are doing (to the extent that I'm aware of the action)....

To repeat.

WTT is a tax specialist in this area.

A couple of years ago we added a Legal function to our company.

We also sought and established relationships with IOM law firms, with a view...