Legality of Loans
Dear HM Revenue and Customs,
I have received a letter from HM Treasury stating that:
1. "It is the view of HMRC and the courts that these schemes have never been effective and that tax was always due"
2. "The most well known judgement was the unanimous Supreme Court decision in favour of HMRC in the Ranger Football case"
3. " Furthermore, the tax consequences the DR schemes claimed to achieve were not allowed under the law at the time".
Please can I have specific information on:
a) What court rulings are HMRC pointing to that would overturn Rangers (as Rangers said it was an employer liability and employer liability cannot be transferred to an employee)
b) What specific laws/regulations are HMRC relying on to say " were not allowed under the law at that time"
Yours faithfully,
Arthur Lewis
Our ref: FOI2018/02760
Dear Mr Lewis,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 14th December which has been passed to
HMRC's Freedom of Information Team.
We have allocated the above reference which you should quote if you need
to contact us.
The Team will arrange for a reply to be sent to you which will either
comply with HMRC's obligations under Freedom of Information Act or, if we
think it's an enquiry that we don't need to address under the terms of the
Act, let you know why. If it is the latter we will, if possible, pass it
on to a more appropriate part of the Department for answer.
Yours sincerely
HMRC Freedom of Information Act Team
Dear Mr Lewis
I am writing in response to your request for information, received 14
December 2018.
Yours sincerely,
HMRC Freedom of Information Team
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