The Counter Avoidance Clearance team within HMRC has been writing to members of the Ingenious Partners 2 LLP, to inform them that the opportunity to reach an agreed voluntary settlement to their tax avoidance dispute, is going to be withdrawn on 31 October 2014.
The appeals in the cases of Inside Track Productions LLP, Ingenious Film Partners 2 LLP and Ingenious Games LLP are due to be heard by the First Tier Tax Tribunal on 3 November 2014, so HMRC has decided to withdraw the settlement opportunity before the commencement of litigation.
The generic letters read as follows:
Withdrawal of Settlement Opportunity: Ingenious Film Partners 2 LLP
We wrote to members of the above partnership in January 2013 offering them the opportunity to settle the tax issues arising from their involvement with the partnership.
In those letters we said that ‘…as litigation nears it will become more likely that we will consider the dispute is no longer appropriate for this settlement opportunity’.
As you will be aware, appeals in the cases of Inside Track Productions LLP, Ingenious Film Partners 2 LLP and Ingenious Games LLP will be heard by the First Tier Tax Tribunal on 3 November 2014.
HMRC has decided to withdraw the settlement opportunity for members of the above partnership on 31 October 2014. We very recently wrote to all members individually to notify them of this. Attached is a redacted version of this letter, with only references to specific partnerships and taxpayers removed.
In these letters, we have explained to members that if they wish to take advantage of the opportunity before it is withdrawn, they should phone 03000 530435, or e mail firstname.lastname@example.org with details of their cash contribution to the partnership, before 31 October 2014.
Details of the opportunity are on the HMRC website at the following address http://www.hmrc.gov.uk/press/uk-gaap.htm
We have advised members to talk to their agent immediately if they have any queries about this.
HM Inspector of Taxes
Further details about the settlement opportunity and FAQs are available on the HMRC website
Abbey Tax and our friends at Leonard Curtis are running a series of seminars during November to outline the options available to participants of tax avoidance schemes. The seminars will run from 8.30am (registration from 8am) for approximately 40 minutes. Breakfast and refreshments will be provided free of charge.
The seminars will cover the following options:
- Discounted settlements with HMRC pre March 2015
- Deadlines for payment, payment terms and available solutions
- Payment options
- Restructuring possibilities
The dates and venues are:
Leeds – Wednesday 12 November, Bewley Leeds Hotel
Birmingham – Tuesday 18 November, Ramada Birmingham, Sutton Coldfield
London – Wednesday 19 November, Copthorne Tara Hotel, London Kensington
Manchester – Wednesday 26 November, Hilton Manchester Airport
If you would like to attend one of the seminars, please e mail email@example.com to register your interest.
Author: Guy Smith, Tax Investigations Manager on the ReSource Tax and VAT Consultancy Team