what do you identify as the tax risk factor introduced by the planning?
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(1) volunteers have to explain scheme & roles to ppl dropping goods http://www.taxation.co.uk/taxation/Articles/2010/01/06/254311/it-s-my-bag …
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(2) artificially low commission rate?
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4 a thing 2b a tax risk factor there has 2b tax law by reference 2 which the tax might b understated
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Replying to @_ClairQuentin @MForstater and
so in order to get a positive from my test you would need to have identified that relevant tax law
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Section 416, Income Tax Act 2007 Condition A 'the gift takes the form of a sum of money'?
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nearly there ... gift is structured 2b money, so you need a basis for looking behind the structure
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Replying to @_ClairQuentin @MForstater and
fwiw imo, 1st pro-purposive. Nothing artificial about relieving gift-aided profits.
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Replying to @JolyonMaugham @MForstater and
2nd 'bad'. Anti-purposive to gift aid on goods. Agent sale not business reality.
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Replying to @JolyonMaugham @MForstater
seemingly, but as
@hselftax points out, HMRC condone this planning, so risk profile more nuanced even than that2 replies 0 retweets 0 likes
nonetheless risk >booking as inkind gift (eg.Risk of getting wrong)=turning pt for yr model?
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the q. of where mitigating implementation risk fits into my model is complex - I should blog about it!
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