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HMRC "almost certain" to appeal


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Will HMRC have the brassneck to appeal? Surely they'd be better sorting out themselves inhouse for a start & investigating whichever of their employees was responsible for the leaks throughout the RTC. Maybe some of their employees have allegiances which make them want to disregard the confidentiality requirement of their jobs. I think I can guess those allegiances.

Why would they appeal ? they're not going to get any money. They will have caused the eventual liquidation of our oldco chasing taxes they weren't entitled to as per last tuesday's verdict. They shouldn't have been main creditor whilst we were in administration trying to get a CVA. That should have been ticketus who'd approved the CVA.

Edited by RANGERRAB
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Will HMRC have the brassneck to appeal? Surely they'd be better sorting out themselves inhouse for a start & investigating whichever of their employees was responsible for the leaks throughout the RTC. Maybe some of their employees have allegiances which make them want to disregard the confidentiality requirement of their jobs. I think I can guess those allegiances.

Why would they appeal ? they're not going to get any money. They will have caused the eventual liquidation of our oldco chasing taxes they weren't entitled to as per last tuesday's verdict. They shouldn't have been main creditor whilst we were in administration trying to get a CVA. That should have been ticketus who'd approved the CVA.

While its true to say any financial reward would be minimal, by taking it to the Upper Tier a victory for HMRC would allow them to have a precedent for any future cases.

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I don't know how strong that precedent would be considering they lost the first tier. All it does is say that the whole thing is muddied and unfair for pursuing companies for the tax. The need to stop offering tax breaks that are based on "discretionary" notions.

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I believe any appeal MUST be based on a point of law.

 

Since the accountant, Dr Heidi Poon found against Rangers, the other two were law experts and found for Rangers. Maybe in HMRC's rarified world, one accountant trumps two legal experts?

 

Further, it will be a new three person committee if an appeal is progressed. Again, it's my belief it will take at least 18 months as there is an 18 month time elapse for a slot. An appeal might not deliver a verdict until 3 years hence.

 

I think someone must calculate both the monetary and opportunity cost of appeal action.

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I don't know how strong that precedent would be considering they lost the first tier. All it does is say that the whole thing is muddied and unfair for pursuing companies for the tax. The need to stop offering tax breaks that are based on "discretionary" notions.

Precedent cant be used as a result of a ruling in the FTTT but can in the UTTT.

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According to Dr Heidi Poon CA, CTA, PhD

 

Can we trust her findings when she states this on page 102 para 121 of her dissenting opinions

 

121. The occasion of Rangers winning the UEFA championship led to six sub-trusts

being created for Mr Warwick, Mr Camden, Mr Islington, Mr Kensington,

Mr Balham,

 

????????

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According to Dr Heidi Poon CA, CTA, PhD

 

Can we trust her findings when she states this on page 102 para 121 of her dissenting opinions

 

121. The occasion of Rangers winning the UEFA championship led to six sub-trusts

being created for Mr Warwick, Mr Camden, Mr Islington, Mr Kensington,

Mr Balham,

 

????????

 

Sometimes it really makes you wonder.

 

(Then again, even from "our own, well trained lines" we occasionally have suffer the club vs company mix-up.)

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