This is a draft memo to the FST (by then Jesse N).
Interesting that the “retrospection” challenge was reworded.
1/11
Interesting that the “retrospection” challenge was reworded.
1/11
Again, this is one of the causes of dissonance.
HMRC’s “belief” is based on experience of dealing with the wealthy tax avoiders and presumably very little action taken in relation to contractors for so many years.
2/11
HMRC’s “belief” is based on experience of dealing with the wealthy tax avoiders and presumably very little action taken in relation to contractors for so many years.
2/11
A very sad by-product of Brexit. Had the 2019 election not taken place, the retrospective nature of the loan charge might have been removed.
3/11
3/11
4/11
5/11
6/11
7/11
More evidence of dissonance in para 26. In a tax pro's eyes, esp. one dealing with investigations, the fact that an enquiry notice has been issued could never be forgotten. Normal people, however, are entitled to forget it and its significance after years of HMRC inactivity.
8/11
8/11
This is a clue that HMRC were doubling down rather than trying to do the right thing. What is so wrong about admitting a mistake?
9/11
9/11
10/11
11/11
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