What you need to know
Film schemes or sideways loss schemes
A significant number of these ‘avoidance schemes’ have now been defeated in the courts, and HMRC has issued follower notices and accelerated payment notices (“FNs” and “APNs”) on others, meaning people have had to lay out a lot of money or suffer the consequences.
Many people have had various demands across multiple years from HMRC and have discovered that unwinding the effect of film schemes can be complex. It is also sometimes the case that where arrangements were used over a number of years, HMRC has not opened tax enquiries or raised assessments – so sometimes the exposure is less that individuals believe that it is.
Where film schemes have been defeated in the courts, or where promoters are no longer pursuing or assisting with appeals, we can help establish what the actual amount payable might be and to bring everything together to a conclusion. We have helped clients understand what their actual exposure is to HMRC with respect to assessments for tax and assist with settlement, including time to pay for a many people. We can also make sure HMRC is not breaching the legislation – and it does happen.
We can of course assist with appeals where it is appropriate – but we like to be commercial. We don’t recommend fighting if it can’t be won. Frequently our mandate is to bring everything outstanding to an end in a manageable way, so that our clients can continue without the stress of continual demands for information, money or other correspondence from HMRC.
Whether you are looking to understand what routes you have to appeal, or wish to try to conclude in a manageable way, we can help you understand where you are currently, evaluate your options and move your case forward.