We act for a client who invested in what HMRC would class as a tax avoidance scheme. He invested in a film business and funded this through a small amount of his own cash and a large loan which only needed to be repaid from the profits of the business. In the first year a large trading loss arose which was offset against his other income. We inherited the client from another adviser and to date negotiations with HMRC have been undertaken by the promoters of the scheme. Our client has now received a letter under the settlement opportunity announced on 3 December 2012 and we have been asked by the client whether he should contact HMRC to seek settlement. If the settlement is accepted he will face a large tax bill.
Which schemes does the settlement opportunity apply to? HMRC is offering...
