CLSO Settlement - Historic Appeal
A little about my situation. I'm currently trying to get all my affairs in order with HMRC and am going through the CLSO settlement process at the moment. This includes EBT schemes (I won't name them, just schemes A, B, etc.) I was involved in in tax years
06/07 - Scheme A & Scheme B
07/08 - Scheme B & Scheme C
08/09 - Scheme C
I've passed on all my relevant information to HMRC and they have come back to me with an initial set of calculations. The problem is that I believe I settled the 06/07 Scheme A enquiry via an APN I received in 2015. When I've come to look into this more closely it seems HMRC calculated the APN on total earnings which were estimated at £10K above what I actually received. In my current CLSO calculations they seem to acknowledge part of this APN payment, but not the amount I overpaid.
I have made it clear to HMRC in my CLSO settlement reply that I made a greater contribution to the APN in 2015 than they are currently considering and that I expect this full amount to be contributed towards any settlement figure they supply for all three years. Is this a reasonable request or do I have to make a tribunal request for the 2015 APN calculation? Can I even make a tribunal request four years later or is there another review option open to me or do I continue to argue my case with the current CLSO settlement for the full 2015 APN settlement figure to be taken into account?