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  1. The best way to have the client say you are...

    The best way to have the client say you are outside IR35 is to work in a manner compliant with the rules.

    The contract is always secondary to the facts. No amount of clever wording will alter...
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    HMRC has said no targeted IR35 investigations. ...

    HMRC has said no targeted IR35 investigations.

    Do you believe them?

    I'm a tax adviser and I don't.

    I predict rather than enquiries will be made. A burst in Q1 next year and then more which...
  3. Just be aware that words in a contract mean...

    Just be aware that words in a contract mean little without being backed by real working practices matching the words.
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    A loan write off is taxable. When you settle,...

    A loan write off is taxable.

    When you settle, the terms (usually) say that the tax paid via the settlement will prevent a charge on a subsequent write off being taxable. This carries a condition...
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    First - go and get advice. You are probably...

    First - go and get advice. You are probably discussing a significant sum here and if it was in relation to buying a big asset, providing for your family, etc, you would get advice. Not from an...
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    I would have to say that this is inaccurate. ...

    I would have to say that this is inaccurate.

    PM me with a phone number and I'll call you.
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    A few thoughts here. Those who used Pembroke...

    A few thoughts here.

    Those who used Pembroke (or any of its 14 - and counting - connected outfits) will have entered into a series of agreements. That is a legally binding agreement that carries...
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    Please be careful here. The title of the...

    Please be careful here.

    The title of the thread "trust demanding repayment" is inaccurate. The trustee - Pinotage - has allegedly sold the creditor rights that they held to another firm.

    Do...
  9. How much is the contract worth? Go and get...

    How much is the contract worth?

    Go and get advice the cost of which will be a small fraction of that?

    How much risk are you and your client willing to take on?

    Go and get advice the cost of...
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    Start here. About - Giles Morris...

    Start here.

    About - Giles Morris
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    I have no knowledge of the claimed sharing of the...

    I have no knowledge of the claimed sharing of the report with HMRC (although I did hear yesterday that one of the witnesses interviewed had been contacted by Sir Amyas to say this) and no sight of...
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    Yes I do have them. I'm not going to post them...

    Yes I do have them.

    I'm not going to post them here.

    If you used the scheme, you would have had the missive I referred to and the relevant contact details.

    I'm aware that one contact will be...
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    Umbrella companies can be quite creative in how...

    Umbrella companies can be quite creative in how they quote.

    Any take home rate above 70% should be carefully examined.

    Look out for:

    High levels of expenses take up which are unacheivable....
  14. The description in that post is not one I've...

    The description in that post is not one I've encountered and is not - to the best of knowledge - the modus operandi adopted in the Procorre versions I've seen.

    Consequently, I have no view or...
  15. As this is not really a Procorre question, I'll...

    As this is not really a Procorre question, I'll immediately break my own embargo and answer.

    In terms of complexity where the most intricate and contrived scheme is a 10, the early Procorre...
  16. This will be my final post on Procorre and its...

    This will be my final post on Procorre and its predecessors.

    Having read all the available materials and considered carefully their relationship with money flows and the suggested means of...
  17. In terms of proof, some hearsay sales patter is...

    In terms of proof, some hearsay sales patter is not the strongest.
  18. Do you have any written material as to your...

    Do you have any written material as to your understanding above?

    Materials I have read on the scheme - admittedly dated in 2019 - do say if you read them all the way through that the profit share...
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    Yes. However a write off now without the...

    Yes.

    However a write off now without the comfort of a settlement agreement that states unequivocally that no further tax charge can arise, would not be sensible.
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    You pepper your posts with constant references to...

    You pepper your posts with constant references to you, your history, your story and how factors from years ago can influence what will happen in 2020. In the face of pretty much all other posters...
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    Thank you and likewise.

    Thank you and likewise.
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    This thread is not about you, your history, your...

    This thread is not about you, your history, your circumstances or how you dealt with them.

    This thread is to discuss what an alternative to IR35 might look like.

    We have (I think) reached a...
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    Well you have a choice of hearing different...

    Well you have a choice of hearing different views, weighing them and deciding which is better/best.

    Or you can have clear water which may be deep and treacherous.
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    yes it is. I've said before here that the...

    yes it is.

    I've said before here that the sections mentioned above are all in the part of the act dealing with disguised remuneration. In order to "benefit" from them, you have to accept that the...
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    Not entirely true. If you have settled via the...

    Not entirely true.

    If you have settled via the present (suspended) settlement opportunity, then a write off within the allocated time (30 days?) will not attract a liability.

    A settlement...
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    I agree that spending time worrying about things...

    I agree that spending time worrying about things that might happen is pointless.

    However, preparing for things that are likely to happen is sensible.

    The write off of the loan is a TAXABLE...
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    The webinar was not about policy but a session...

    The webinar was not about policy but a session designed to help people understand the process, the rules, the application.

    I can understand no reason why it was cancelled.
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    Thank you for the kind words. I'm sure that...

    Thank you for the kind words.

    I'm sure that people are entitled to their opinion and let's be honest, most of what we claim is not yet proven in Tribunal.

    What I remain interested in is any...
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    There is no correlation between DOTAS and loans....

    There is no correlation between DOTAS and loans.

    There is no correlation between what the promoters claimed the money was and what HMRC (and the Courts probably) think it was.

    Ultimately...
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    The trustees may have decided that cash in hand...

    The trustees may have decided that cash in hand is more useful to beneficiaries than the uncertain prospect of collecting on the loan?

    The only way you'll know is to ask them.
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    No. An EFRBS is just a trust. A trust holds...

    No.

    An EFRBS is just a trust. A trust holds assets that in due course are to be used for the beneficiaries. In the case of a highly regulated environment such as the UK, there are rules about how...
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    It's really not that difficult. A loan is just...

    It's really not that difficult.

    A loan is just an asset for the lender and a liability for the borrower.

    The lender in this instance was said to be either K2 - an offshore company - or Hyrax...
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    With respect, that is an unsustainable position....

    With respect, that is an unsustainable position.

    Laws are specific in what they apply to. The ability of a result obtained under one set of laws to "frank" the outcome of a different set of laws,...
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    Having loans written off without first agreeing a...

    Having loans written off without first agreeing a settlement with HMRC is not recommended.

    First, such a write off now will not impact the loan charge liability.

    Second, a loan write off is a...
  35. National debt £1.84tr One off benefit from...

    National debt £1.84tr

    One off benefit from contractor world - around £3bn.

    Annual effect of IR35 reform (i.e. additional tax) perhaps £1bn on a very good day.

    In 1,000 years, all will be...
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    IR35 and election purdah

    There was meant to be an HMRC webinar today on IR35 reform and actions.

    It has been cancelled due to election purdah.

    Over sensitive?
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    I think that action might breach some forum...

    I think that action might breach some forum rules.

    I would say that all and any advisers in this space will have concerns about this latest news and will be doing their best to prepare for...
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    Calculate interest and penalties for the tax...

    Calculate interest and penalties for the tax years ended 5 April 1998 to 5 April 2018 - GOV.UK

    Go here and follow the links.
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    Really? I suspect that many thousands of...

    Really?

    I suspect that many thousands of employees manage to support a family and save.

    I would go further and say that given that the ratio of employee to self employed/contractor in the UK...
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    Not a view shared by HMRC units dealing with this...

    Not a view shared by HMRC units dealing with this sector.

    But you are correct.

    MPs/HMRC will score no PR points for slagging off farmers.
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    I think I'd be tempted by a measurement of...

    I think I'd be tempted by a measurement of available cash vs invested profits.

    Those companies which are within the scope of ER would be where they may have made profits but who are cash poor...
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    And I can tell you that compared to farmers,...

    And I can tell you that compared to farmers, contractors are beginners in the tax avoidance world.
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    I was not drawing a comparison between...

    I was not drawing a comparison between industries.

    I was trying to point out that the argument that employees pay more tax than contractors is usually based on a comparison of earnings over one...
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    Let me float an idea. Farmers are subject to...

    Let me float an idea.

    Farmers are subject to seasonal fluctuations in prices etc. As such they have an "averaging" basis available to them by which they can average profits over a number of years,...
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    Yes they are. If you feel like that, get in...

    Yes they are.

    If you feel like that, get in touch with LCAG.
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    It's an unholy mess. Worst case scenario. ...

    It's an unholy mess.

    Worst case scenario.

    You complete the SATR with the loan details. You cannot and therefore do not pay the LC as it appears on your statement. The amount due passes into the...
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    I understand that the letter from FS has been...

    I understand that the letter from FS has been followed by two messages from somebody who might be described as the promoter of the arrangement. These messages say that the "promoter" was unaware of...
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    Last time I looked HMRC statements were not law,...

    Last time I looked HMRC statements were not law, could not be made law and did not override the law.

    My clients are being advised that YES you need to complete the SATR regardless of the loan...
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    Take a deep breath and read the letter again.

    Take a deep breath and read the letter again.
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    And there you have one reason why this has never...

    And there you have one reason why this has never become policy or law.

    For the record I was not suggesting that the working dividend rule was an alternative, just that it was one response...
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