Neil Patterson is crowdfunding
Weʼre raising £1,000,000 to Help Fight HMRC's Unfair Litigation!
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Story
Incorporated rental property business owners and the vital services of Property118.com are at risk. We need your support to stand up against HMRC's unjust actions.
BACKGROUND
In February 2024, HMRC issued Scheme Reference Numbers (SRNs) to Property118 and its clients under the Disclosure of Tax Avoidance Schemes (DOTAS) legislation. Industry professionals have likened this to placing a "KICK ME" sign on the backs of these businesses and their owners.
Property118 swiftly appealed HMRC’s decision to the Tax Tribunal on 5th March 2024, arguing that the recommendations made by Property118 did not provide any tax advantages beyond those intended by legislation and HMRC's extra statutory concessions established over 50 years ago. HMRC was copied into the full details of this appeal on the basis that this would give HMRC more time to reconsider its position and to avoid delays due to the Tribunal having a two-month backlog of work.
On 10th May 2024, the Tax Tribunal finally gave HMRC 60 days to make a “Statement of Case” to justify their actions. One would expect HMRC to respond promptly, especially given that Property118 informed them of the appeal shortly after it was submitted. If HMRC truly believed they had good reason for issuing the SRNs, why did they subsequently apply to the Tax Tribunal Judge to delay the presentation of their case?
Worse still, HMRC wanted to split our Appeal into two separate cases (even though the arguments are largely similar) and double the legal costs for our appeal.
By the deadline of 9th July 2024, HMRC would have had almost five months to justify its actions. Instead, their solicitors have used delay and procedural tactics that drain Property118’s resources, preventing us from assisting other landlords and incurring additional legal costs, further depleting our financial reserves to dangerously low levels. The outcome of this is that as of 1st July 2024 the Tax Tribunal Judge issued new directions granting HMRC a further 60 days to submit their Statement of Case.
In summary, HMRC has got its way and managed to ‘kick the can down the road’ yet again. Assuming they don’t manage to delay the justice process even further it will have been well over six months by the time they provide proper justification for their actions. This is badly impacting our ability to trade to remain in business. This is because we (and all other professional advisers) cannot, with a clear conscience, assist any other landlords to incorporate as a result of the uncertainties created by HMRC’s actions.
HOW YOU CAN HELP
We are raising funds to ensure Property118 has the necessary resources to see this legal battle through to the end. Justice can only prevail if we have the funds to continue fighting against HMRC's unfair litigation practices.
Your support will help us to:
- Cover ongoing legal expenses
- Sustain our operations and support services for landlords
- Challenge HMRC's unjust actions and seek a fair outcome
Join us in this critical fight for fairness. Every contribution makes a difference and brings us one step closer to justice.
Thank you for your support.
From Underdog to Champion
We did it once. We can do it again.
The Property118 Action Group made history when we successfully challenged the West Bromwich Mortgage Company, securing millions in overpayments for landlords across the UK. Our victory was a landmark achievement for the property industry.
We’ve encountered both overwhelming gratitude and unexpected criticism. Some have questioned our motives, even those we helped previously. It’s a stark reminder that while we strive to do right by everyone, it’s impossible to please all.
Your support is crucial as we continue to fight for fair treatment and protect the rights of landlords. By donating, you’re not just helping us; you’re investing in a stronger, fairer property industry.
Proof of our success:
It is time to say ‘enough is enough’ to HMRC.
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Updates
7
6 days ago
Neil Patterson
6 days agoThe target has been increased to £1,000,000. That level of funding may be needed if the case is dragged to the Upper Tier Tribunal, as the Elizabeth Moyne Ramsay case was back in 2013 when HMRC unsuccessfully challenged her eligibility to claim incorporation relief. Also, please bear in mind that Property118 Action Group lost at Ombudsman and High Court before justice was finally served to the West Brom Mortgage Company at the Court of Appeal. Your donations will provide the vital resources for us to continue to fight this battle for Justice.
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11 days ago
Neil Patterson
11 days agoCompare and contrast our guidance at https://www.property118.com/tax/#_Toc170196340 with the utter drivel shared by the former Head of Tax at a 'Magic Circle' law firm in the screenshot below
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11 days ago
Neil Patterson
11 days agoFurther updates will follow in due course. Meanwhile, thank you to all who have supported our fundraising campaign so far. Neil Patterson Managing Director of Property118 Limited
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Neil Patterson started crowdfunding
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Supporters
133
ZAHER.WALJEE@GMAIL.COM
Jul 15, 2024
KEEP FIGHTING AND DO GOOD WORK
£80.00
Anonymous
Jul 15, 2024
£10.00
Anonymous
Jul 15, 2024
£50.00
Tim Randall
Jul 15, 2024
Hi Mark, Second £1,000 for the £2,000 donation. If this can be resolved with HMRC it will take a lot of stress and worry for everyone. Your business will also thrive with new business . Good luck
£1,000.00
Bernie Sloane
Jul 15, 2024
This is the 1st payment l will make each month over the next 4 months Keep up the good work
£500.00
Yiuyiu Li-Rahman
Jul 15, 2024
£10.00
Peter Wood
Jul 15, 2024
Property118 is a great benefit to landlords who own property ut also clarifies tenants responsibilities as renters - it's not dissimilar to hiring a car, fixed term, look after it, any damage you pay!
£25.00
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