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HMRC launches new settlement opportunity

28th Jan 2013
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HMRC has published the terms of a new settlement opportunity open to participants they believe have entered into schemes which seek to get more tax relief than the “real economic cost that they have borne”.

Following news in December of additional investment in the clampdown on tax avoidance and evasion, HMRC invited participants in a variety of schemes to settle their tax liabilities by agreement, without the need for litigation.

The schemes covered include those:

  • accessing film relief for production expenditure
  • creating losses in partnerships through capital allowances or payments for restrictive covenants
  • using GAAP to create losses by writing off expenditure or the value of assets

According to HMRC this settlement opportunity offers the “best opportunity” to resolve these disputes in a way which is “cost-effective and consistent with the law”.

It added that where people decline the opportunity, they will “increase the pace of our investigations and accelerate disputes into litigation.

“As well as continued uncertainty, delay in resolution, additional costs and potential reputational damage, taxpayers who choose the litigation route may end up with a worse tax result than they would obtain under the settlement opportunity,” an official statement read.

HMRC aims to contact all those who are eligible for the offer, made in accordance with its Litigation and Settlement Strategy, by 31 January.

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By janice.stephen-hill
05th Feb 2013 10:15

HMRC Settlement Opportunity for Film Partnerships

We have a few clients who invested in Film Partnerships a number of years ago and who have now received notification that they are eligible to take up the Settlement Opportunity in respect of those investments.

Obviously it has to be a personal choice for the client as to whether to take up the offer or not, but does anyone have any opinions on this or experience with this yet?

Just wondering if anyone has come across any unexpected difficulties that it would be useful to be aware of.

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