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I make the following brief reflections on the Hoey proceedings.
They reflect solely my perception of the oral arguments and should not be taken as any comment on what the law actually says/means.
In short, I am pessimistic about Mr Hoey’s chances of success.
1/9
#hoey
They reflect solely my perception of the oral arguments and should not be taken as any comment on what the law actually says/means.
In short, I am pessimistic about Mr Hoey’s chances of success.
1/9
#hoey
It must be remembered that there are a number of different issues – ultimately representing HMRC’s different lines of attack.
2/9
2/9
HMRC’s most ambitious approach was to invoke the “transfer of assets abroad” code – this met strong resistance from the Court and I expect the Court to find in Mr Hoey’s favour on this point.
That leaves the case squarely in the realm of employment taxes and the PAYE rules.
3/9
That leaves the case squarely in the realm of employment taxes and the PAYE rules.
3/9
