Hi! I understand new schemes are being used in mitigating the SDTL liability but then HMRC are also trying to catch up with such schemes and even extended their assessment period to 20 years. How good are the schemes these days and is it just a question of initiating them with some risk of repaying the liability in the future and hoping that HMRC would not have enough resources in the future to actually tackle them?Basically would it be just an exercise "Save now-pay later with interest" but possibly without the penalties if proper advice has been provided so no penalty liability for the purchaser? Thank you in advance
Subject: RE: SDTL
Hi Andrew, I think that both HMRC and the tax tribunal would take a very negative view of a taxpayer who engaged in a tax scheme simply as a deferral device and "lawyered-up" at the same time in order to try and protect himself from penalties. The deferral may be defeated by the issue of an accelerated payment notice and I doubt that a decent lawyer would be willing to give a positive opinion in such circumstances in any event.