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Armadillo - Tax Support Profile picture
Armadillo - Tax Support
@ArmadilloSupprt
Supporting #contractors through a maelstrom of legislative changes including the Loan Charge, IR35 & MSC.
Charles Underwood Profile picture 1 subscribed
Jun 3, 2021 • 4 tweets • 1 min read
Facts these letters omit to mislead.
1. RFC is NOT authority that loans are taxable but that PAYE ought to have been deducted by the employer.
2. Hoey FTT found income of person abroad that could be taxed under ToAA code was nil.
3. UT dismissed HMRCs appeal on that point. Cont.. 4. Hoey’s appeal dismissed only on jurisdiction as HMRC argued the tax tribunals cannot determine how much tax should be paid when HMRC exercise a discretion they had not raised until May 19.
5. UT went in to say that HMRC couldn’t retrospectively remove PAYE credit.
Cont.
Apr 29, 2021 • 6 tweets • 1 min read
A thread on the mockery HMRCs pleadings re their unfettered discretion under s684(7A) make of the PAYE system & taxpayer protections..... 1. In Hoey HMRC had not raised ANY PAYE determination. Years later HMRC claimed they could retrospectively absolve a party they didn’t assess from obligations they didn’t enforce. And pursue Mr Hoey instead.
Apr 28, 2021 • 4 tweets • 1 min read
Worth stressing that if HMRC can retrospectively exercise discretion under s684(7A) as they (continue to) argue there are no closed years. No time limits. No restriction on the circumstances in which that discretion can be exercised beyond the "satisfaction" of an Officer HMRC. It would mean that the Loan Charge is otiose. It is not & was never needed. It means that time limits for issuing PAYE determinations are redundant where an officer of HMRC is satisfied that it is unnecessary or not appropriate for the payer” to operate the PAYE regs.
Apr 13, 2021 • 12 tweets • 2 min read
A mess of their own making.... thread HMRC’s change of argument in RFC meant that it would be unable to pursue individuals for unpaid PAYE because it had not assessed the right party at the right time & even if it had, the conditions to xfr liability weren’t met. They must (at least should) have know that at the time
Jul 9, 2020 • 10 tweets • 3 min read
Many are being sold hope; a guarded resolution strategy, shielded from peer review. It is suggested by some so blind they won’t see that I support sensible settlement terms to somehow protect “promoters”. Nonsesence & lies. I do so because.... The idea that RFC could mean that the LC could not [also] apply was first discussed by me with Counsel in Autumn of 2017. See this extract from an opinion dated Oct 17.