What To Expect In The Next Few Months And How To Deal With It

12 October 2020

Over the next few weeks and months HMRC will likely begin to start opening tax enquiries for not informing them of the loan charge receipts, failing to complete the disguised remuneration section, or the possibility of other LC related items. This is very much what is expected and should not come as a surprise. In conjunction with the QC, we will be providing template letters to provide the necessary response to HMRC and push back on what they decide to try by way of threats or other action.

The fact that you took professional advice should be sufficient defence to repudiate any penalties and halt the payment of tax demanded. This doesn’t mean HMRC won’t try to impose them in the first place. The pro-forma letters provided will appeal the particular charge and eventually go to FTT where we expect to have a test case to defeat the actions of HMRC for all.

HMRC will probably try tactics of divide and conquer by targeting individuals. If this does happen, then we will aim to rebut those actions. We must all stick together throughout this process and coordinate our efforts. We have therefore put in place a process that enables us to compile, coordinate, and contact that people that receive correspondence from HMRC. This is why we need to hear from individuals if you receive letters from HMRC relating to the LC and your SATR.

If you are contacted by HMRC, or they open an enquiry into your 2018/19 tax return, or write to you for not disclosing your loans or similar, then please contact us at contact@lcjreu.org.uk ensuring “HMRC Letter” is in the subject line. As well as providing the template responses, we need to record what information or notices HMRC are distributing to people who have followed the LCJREU process.

The State Of the Case

11 October 2020

Actions in England and Scotland are well under way. Funding is in place, but not a lot will happen in the case itself as the legal process is rather glacial. We will post updates, at least bi-weekly, just so you know if anything changes; so bookmark this page.