5/13/25, 12:57 PM Current list of named tax avoidance schemes, promoters, enablers and suppliers - GOV.

UK

HM Revenue
& Customs

Corporate report

Current list of named tax

avoidance schemes, promoters,
enablers and suppliers
Updated 8 May 2025

Contents
1. How to use the information on this page
2. Most recently named promoters
3. List of named tax avoidance schemes, promoters, enablers and
suppliers
3. If you’re involved in a tax avoidance scheme
4. Details of how each named scheme is claimed to work
5. Explanation of terms used

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© Crown copyright 2025

This publication is licensed under the terms of the Open Government Licence v3.0 except where
otherwise stated. To view this licence, visit [Link]/doc/open-government-
licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London
TW9 4DU, or email: psi@[Link].

Where we have identified any third party copyright information you will need to obtain
permission from the copyright holders concerned.

This publication is available at [Link]

avoidance-schemes-promoters-enablers-and-suppliers/current-list-of-named-tax-avoidance-
schemes-promoters-enablers-and-suppliers

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1. How to use the information on this

page
If you are involved in any of the tax avoidance schemes shown on this
page, or recognise any of the promoters, enablers or suppliers, you should
contact HMRC as soon as possible. There is more information about how to
do this below. You can also report a tax avoidance scheme to HMRC.

There are other schemes, promoters, enablers and suppliers that HMRC
cannot publish information about at this time. This may be because:

HMRC is gathering information about the promoter, enabler, supplier or

avoidance schemes being marketed
HMRC is considering representations from a promoter, enabler or
supplier
the appeal period for not withdrawing a stop notice has not ended
HMRC is not aware of the tax avoidance scheme, promoter, enabler or
supplier

Read more information about what HMRC can publish, and why
([Link]
promoters-enablers-and-suppliers/information-hmrc-may-publish-about-tax-
avoidance-schemes-promoters-enablers-and-suppliers).

If you want to get more information about a company or its directors, you
can check Companies House ([Link]
company).

You can also check the list of tax avoidance schemes subject to a Stop
Notice ([Link]
schemes-promoters-enablers-and-suppliers/list-of-tax-avoidance-schemes-subject-
to-a-stop-notice).

2. Most recently named promoters

The most recent additions and updates to the list of named tax avoidance
schemes, promoters, enablers and suppliers in section 3 below were
published on 8 May 2025.

Updates:

Contractor Bureau Limited

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3. List of named tax avoidance schemes,

promoters, enablers and suppliers
This list is presented in alphabetical order and is updated regularly. If you
recognise any name on this list and are concerned you’re involved in a tax
avoidance scheme, please contact HMRC.

A to C D to F G to I J to L M to O P to R S to U V to X Y to Z

This is not a complete list of all tax avoidance schemes currently being
marketed. Neither is it a complete list of all promoters, enablers and
suppliers.

If a tax avoidance scheme is not shown in the list, this does not mean that
the scheme works or is in any way approved by HMRC. HMRC does not
approve tax avoidance schemes for use.

A to C
ABC Umbrella Ltd
Abchurch LTD
Acacia Management Services Limited
Accent Umbrella Ltd
Acquda Limited
Acquda Solutions Limited
Adapt Limited (Based in Isle of Man)
Adept Pay – see Summit LED Ltd
ADYE Ltd (Based in Cyprus) – see Apricot Umbrella Limited
Agile Pay Ltd
AI Global Workforce Ltd
Alphasaint Ltd
AML Tax (UK) Limited
Apricot Umbrella Limited
Astra Limited
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B2BTradecard Ltd
Back Office Assistance 1 Limited
Back Office Services 1 Limited
Back Office Systems 1 Limited
Balance Bay Limited
Balance Bay Services Limited
Bestia Holdings Ltd (Incorporated in Cyprus) – see Dalespay Ltd
BHD Consultants Ltd – see Miwsa Limited
Blizzard Pay Ltd
Bluemoore Associates Ltd
Bluestar Financial Solutions Limited
Bonzai Umbrella Limited – see Universe Payroll Limited
Buckingham Wealth Ltd (Incorporated in Belize)
Burnsall Pay Ltd
Calculate Limited
Canopaye Limited
Century Umbrella Limited
Charteris Management Ltd
Clear Water Administration Limited
Compliant Pay Ltd
Connection Point Ltd
Consortius Solutions Limited
Contractor Buddy PCC Limited (Incorporated in Isle of Man) – see
Payeworx Ltd
Contractor Bureau Limited
Contractor Corner Accounting Limited – see Optima Limited
Contractorcare Ltd
Corre Holdings SA (Registered in Switzerland) – see Procorre LLP
Cotswold Barristers Ltd – see Property118 Ltd
Countryside Capital Ltd – see United Pension Administration Ltd
Countrywide Partners Limited
Cube Umbrella Limited

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This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers.

D to F
Dalespay Ltd
Denmedical UK Limited – see AML Tax (UK) Limited
Deposlo Holdings Ltd (based in Cyprus) – see Edge Umbrella Limited
Dynasty Payroll Solutions Ltd – see Greenlight Payroll Services Limited
and Rosewood WM IO Services Ltd
Earneze Limited
Easyway Umbrella Limited
Edge Umbrella Limited
Employe Limited
Employe US Limited
Everest Contracting Limited
Excala Solutions Limited
Expertise Solutions Limited
Fast Payroll UK Ltd
Fastpay - see Fast Payroll UK Ltd
1st Choice Umbrella Ltd
First Paye Consultants Limited
Flex Payroll and Accounting Services Ltd
Flexen Ltd (Incorporated in Cyprus) – see Rainbowpay Ltd
Focus Contractor Limited
Frank Umbrella Limited – See Adapt Limited and Optima Limited

This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers.

G to I
GL Premium Ltd

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Goldfish Umbrella Limited

Greenlight Payroll Operations Ltd – See Greenlight Payroll Services
Limited
Greenlight Payroll Services Limited
Griffith Anderson Limited – see Charteris Management Ltd and The
Umbrella Agency Limited
Hamilton Bradbury Ltd
Hive Umbrella Ltd
Howe Consultancy Limited (Incorporated in Isle of Man) – see Charteris
Management Ltd
HRG Consulting Ltd – see Miwsa Limited
HWX Consulting Ltd – see Miwsa Limited
Imace Limited
Infrapro Consulting Limited
Integra Resourcing Limited (Incorporated in Malta) – see Charteris
Management Ltd
Innovate Limited (Registered in the Isle of Man)
Intu Solutions Limited
IP Global Consulting Ltd

This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers.

J to L
JBatts Ltd – see Miwsa Limited
Jeceris Limited – see Charteris Management Ltd
Jigsaw Pay - see Jigsaw Payment Solutions Limited
Jigsaw Payment Solutions Limited
JJDM Consulting Ltd – see Miwsa Limited
Just Standard Limited
K & B Umbrella Ltd
Knight & Bishop – see K & B Umbrella Ltd
Knight and Bishop Services – see K & B Umbrella Ltd
Krevit Ltd – see ABC Umbrella Ltd
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Langan Scott and Co Ltd

Level Up Associates Limited
LWI Services Limited (Address in British Virgin Islands)

This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers.

M to O
Masterstroke Solutions Limited
Medbridge Ltd
Minerva Services Ltd (Incorporated in Belize) – see Buckingham Wealth
Ltd
Miwsa Limited
Miwsa Management Ltd
MLG Pay Limited
Mountain View Admin Limited
Mountain View Administration Limited – see Mountain View Admin
Limited
New Mill Resourcing Ltd
Odyssey Payroll Limited
Olympus Contracting Limited
Ombros Solutions Limited – see Charteris Management Ltd
Omni Contractors PCC Limited (Incorporated in Isle of Man) – see
Pinnacle and Partners Limited, Saxonside Limited and 1st Choice
Umbrella Ltd
On the Box Pay Ltd
Optima Limited (Registered in the Isle of Man)
Saxonside Share Growth

This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers.

P to R
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PAYE Services Limited

PAYEme Ltd
Payeworx Ltd
Pay Rec Limited
Payroll Professors Limited
Paystone Services Limited
Pazepay Limited
Peak PAYE Limited
Penhale Solutions Limited
Pinnacle and Partners Limited
Prime Umbrella Services Ltd
PRC Recruitment Ltd
Procorre LLP (Registered in Singapore)
Property118 Ltd
Protean Ltd
Purity Ltd
Purple Pay Limited
Rainbowpay Ltd
Rainwize Umbrella Limited
React Administration Services Limited
Remuneration Assured Ltd
Resource Hubco Limited
Rosewood WM IO Services Ltd
RW Operations Ltd

This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers.

S to U
Saxonside Limited
Saxonside Share Growth
Signature Pay Limited

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Signature Vintage Limited

SmartPay Limited (Incorporated in the Isle of Man)
Solucionis Limited
Stark Payment Services Ltd
Succeed in Property Ltd – see Property118 Ltd
Summit LED Ltd
Target Umbrella Limited – see Integra Resourcing Limited
Taurus Limited (Incorporated in Isle of Man) – see Charteris Management
Ltd
TGI Payday Ltd – See Adapt Limited and Astra Limited
Titan Payment Solutions Limited
Trident Umbrella Limited
365 Umbrella Ltd
Ultimate Planning Ltd – see Compliant Pay Ltd
Ultra Employment Ltd
The Umbrella Agency Limited
Umbrella Link Ltd
Umbrella Union Ltd
Umbrella Zone Limited
United Pension Administration Ltd
Universe Payroll Limited

This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers.

V to X
Veqta Ltd
Vision HR Solutions Ltd
Vision Human Resource Solutions Ltd
Vortexx Limited
We Are Ava Limited
Whitebridge Management Ltd
Wilson Costello Limited – see Prime Umbrella Services Ltd
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Y to Z
Your Pay Ltd
Your PAYE Limited

This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers.

ABC Umbrella Ltd

Details of persons ABC Umbrella Ltd / Kevin Cutler (Director of

suspected of ABC Umbrella Ltd) / Krevit Ltd (Incorporated in
promoting the scheme, Cyprus) / Giannakis Fysentzou (Director of
or of being a Krevit Ltd)
connected person, or
having any other role
in relation to making
the scheme available
for implementation

Addresses of persons ABC Umbrella Ltd: 1921 Building C/O

suspected of Aspirations Accountancy, East Malling Business
promoting the scheme, Centre, New Road, East Malling, United
or of being a Kingdom, ME19 6BJ / Krevit Ltd: Stratigou
connected person, or Timagia, 15, Linda Court, Floor 3, 6051,
having any other role Larnaca, Cyprus
in relation to making
the scheme available
for implementation

Date of publication 9 August 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients or agencies through
ABC Umbrella Limited as their employer. The
individuals also enter an agreement with Krevit
Ltd where individuals grant the right to enter an
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Annuity Agreement in exchange for payments

(the Grantee Payments). The individuals
receive payment from ABC Umbrella Limited.
However, tax and National Insurance
contributions (NICs) are only deducted on a
small part of the amount. This is evidenced on
the payslips and figures reported to HMRC. It is
HMRC’s view that the larger amount, paid
without tax or NICs deducted, is for the Grantee
Payments, but paid by ABC Umbrella Limited on
behalf of Krevit Ltd. It is also HMRC’s view that
the Grantee Payments are additional disguised
income for services provided by individuals
through ABC Umbrella Limited, and the entire
payment should therefore be subject to tax and
NICs.

Any other information HMRC have previously published Spotlight 60

HMRC considers guidance on agency workers and contractors
relevant to publish employed by umbrella companies. HMRC has
about these schemes now allocated a Scheme Reference number,
60705829, to the arrangements on 26 July 2023
under section 311 Finance Act 2004 ‘Disclosure
of Tax Avoidance Schemes’.

Abchurch Ltd

Details of persons Abchurch Ltd

suspected of
promoting the
scheme

Addresses of 128 City Road, London, EC1V 2NX

persons suspected
of promoting the
scheme

Date of publication 29 February 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

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How the scheme is Individuals provide services to end clients as

claimed to work employees of Abchurch Ltd. Employees receive
part of their Abchurch Ltd remuneration at a rate
close to the National Minimum Wage or National
Living Wage with Income Tax and National
Insurance contributions (NICs) deducted.
Employees receive the balance of their
remuneration, disguised as a loan, credit, or other
payment without Income Tax or NICs deducted.

Any other It is HMRC’s view that all remuneration paid to

information HMRC employees of Abchurch Ltd is taxable. HMRC has
considers relevant to previously published Spotlight 60 on disguised
publish about these remuneration schemes involving agency workers
schemes and contractors employed by umbrella
companies. HMRC is aware that some umbrella
companies operate more than one scheme, for
example, a standard compliant scheme and a
non-compliant scheme. HMRC advises
employees of Abchurch Ltd to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Acacia Management Services Limited

Name of promoter Acacia Management Services Limited (AMS) / Jake

of scheme and Hamill (former director of Acacia Management
connected person Services Limited)

Address of 27 Byrom Street, Manchester, M3 4PF / Former

promoter of scheme address: Office 2.24 Edward Pavilion, Albert Dock,
Liverpool, L3 4AF

Date of publication 11 April 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Scheme users enter into a contract of employment

claimed to work and an option grant agreement with AMS. AMS
invoice recruitment agencies for the services
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provided by the scheme users. On receipt of

payment from the recruitment agencies, AMS pays
a National Minimum Wage or National Living Wage
salary to the scheme users with tax and National
Insurance contributions (NICs) deducted. AMS also
makes a second payment to scheme users,
described as an ‘option grant’, with no tax or NICs
deducted.

Any other HMRC’s view is that the option grant payments are
information HMRC no different to normal income, and tax and NICs are
considers relevant payable. HMRC have previously published
to publish about information about the tax avoidance arrangements
these schemes used by some umbrella companies Spotlight 60.
HMRC are aware that some umbrella companies
operate more than one scheme; for example, a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of AMS to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income. HMRC has
evidence that AMS predominantly worked with
recruitment agencies in the medical sector.

Accent Umbrella Ltd

Details of persons Accent Umbrella Ltd (AUL)

suspected of
promoting the
scheme

Addresses of Unit 1-3 Salisbury Street, Widnes, WA8 6PJ /

persons suspected Previous address: 20-22 Wenlock Road, London N1
of promoting the 7GU
scheme

Date of publication 9 May 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

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How the scheme is Some employees of AUL receive their remuneration

claimed to work made up of 2 elements. The first element is a salary
in line with National Minimum Wage rates that has
Income Tax and National Insurance contributions
(NICs) deducted. However, the second element has
no Income Tax and NICs deducted.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, for example a standard compliant scheme
and a non-compliant scheme. The AUL website
shows examples of contractors working in the
medical and tech sectors. HMRC advise employees
of AUL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount of
tax is being deducted on their income. HMRC also
advise employees to be cautious of following advice
from published promoters to join other umbrella
companies as in its first month of operation 100% of
the employees of AUL had previously been
employed by a previously published promoter.

Acquda Limited

Details of persons Acquda Limited (AL)

suspected of
promoting the
scheme

Addresses of 45-55 Commercial Street, London, E1 6BD

persons suspected
of promoting the
scheme

Date of publication 8 August 2024

Legislation under Finance Act 2022

which this
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scheme/promoter
has been named

How the scheme is The arrangements involve users providing their

claimed to work services to end clients as employees of AL. The
users receive a payment made up of 2 amounts.
The first is a basic salary at or around the minimum
rate permitted under the National Minimum Wage
Act 1998 which is subject to deductions for Income
Tax and National Insurance contributions (NICs).
Scheme users also receive a secondary amount
without deductions for Income Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme and
a non-compliant scheme. HMRC advise employees
of AL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

Acquda Solutions Limited

Details of persons Acquda Solutions Limited (ASoL)

suspected of
promoting the
scheme

Addresses of 50 Princes Street, Ipswich, IP1 1RJ

persons suspected
of promoting the
scheme

Date of publication 5 December 2024

Legislation under Finance Act 2022

which this

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scheme/promoter
has been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients as employees of ASoL.
The individuals receive payment made up of 2
elements for their services. The first element is a
basic salary paid at a rate close to the minimum
permitted under the National Minimum Wage Act
1998 which is subjected to deductions of Income
Tax and National Insurance contributions (NICs).
The individuals also receive a second element
without deductions of Income Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC suspects the
arrangement is targeted at NHS and local council
workers. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
ASoL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

Adapt Limited

Details of persons Adapt Limited (Based in Isle of Man) / David

suspected of Michael Yeomans (director of Adapt Limited) / Frank
promoting the Umbrella Limited (in liquidation) / TGI Payday
scheme, or of Limited
being a connected
person

Addresses of Adapt Limited, 6th Floor, Harbour Court, Lord

persons suspected Street, Douglas, Isle of Man, IM1 4LN / Frank
of promoting the Umbrella Limited, C/O Cg & Co, 27 Byrom Street,
scheme Manchester, M3 4PF / TGI Payday Limited, 145
Grimsby Road, Cleethorpes, England, DN35 7DG
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Date of publication 7 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme users sign a contract of employment

claimed to work and commercial loan agreement with Adapt Limited,
a company based in the Isle of Man. Frank Umbrella
Limited/TGI Payday Limited, both umbrella
companies based in the UK, then enter into an
agreement for the provision of the scheme user’s
services. The UK umbrella companies then contract
the scheme user’s services to a UK
intermediary/agency. The UK intermediary/agency
then contracts the scheme user’s services to the
end client. The end client pays the UK
intermediary/agency for the scheme user’s services,
who in turn pay the UK umbrella companies.
Following the deduction of a fee, the UK umbrella
companies pay the remaining amount to Adapt
Limited. Adapt Limited pays a National Minimum
Wage/National Living Wage salary to the scheme
user subjected to Income Tax and National
Insurance contributions (NICs) and a payment,
described as a loan, pursuant to the loan
agreement, which is made without deductions of
Income Tax or NICs.

Any other HMRC also issued a POTAS Stop Notice to Adapt

information HMRC Limited and TGI Payday Limited on 2 May 2024 and
considers relevant published details of the arrangements on 12
to publish about September 2024. The Stop Notice requires Adapt
these schemes Limited and TGI Payday Limited to stop selling or
promoting the scheme. You can find more details on
List of tax avoidance schemes subject to a stop
notice. Details are listed under Stop notice 29.

Agile Pay Ltd

Name of promoter Agile Pay Ltd

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Date arrangements subject to Stop 21 March 2024

Notice published

Date name of promoter subject to 17 October 2024

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

AI Global Workforce Ltd

Name of promoter AI Global Workforce Ltd

Date arrangements subject to Stop 12 September 2024

Notice published

Date name of promoter subject to 12 September 2024

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

Alphasaint Ltd

Details of persons Alphasaint Ltd (ASL)

suspected of
promoting the
scheme

Addresses of 71-75 Shelton Street, London, England, WC2H

persons suspected 9JQ
of promoting the
scheme

Date of publication 11 April 2024

Information 5 September 2024

updated

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Scheme Reference 93135363

Number (SRN)

Date SRN allocated 16 May 2024

to the scheme

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme users’ total remuneration for their
claimed to work contracts with ASL is artificially separated into 2
elements. The first element is a salary with
Income Tax and National Insurance contributions
(NICs) deducted. The second element is paid
without deduction of Income Tax
and NICs by ASL and it is claimed to not count
as employment income, as it is claimed to be
paid by virtue of a conditional annuity purchase
agreement.

Any other The Scheme Reference Number (SRN)

information HMRC 93135363 was allocated to the arrangements on
considers relevant 16 May 2024. HMRC’s view is that both
to publish about elements of the payment should be treated as
these schemes ‘normal income / as the users’ salary’ and is
therefore subject to Income Tax
and NICs. HMRC has previously published
Spotlight 60 on disguised remuneration schemes
involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant
scheme. HMRC advise employees of ASL to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax
is being deducted on their income.

AML Tax (UK) Limited

We have published details of 3 schemes that have been supplied and/or
promoted by AML Tax (UK) Limited:
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a scheme utilising an annuity arrangement

a scheme utilising an employee benefit trust (EBT)
a scheme utilising a split contract

AML Tax (UK) Limited – Annuity Arrangements

Name of scheme Annuity Arrangements

Name of promoter AML Tax (UK) Limited (AML)

or supplier of
scheme

Address of 1st Floor, Blackfriars House, Parsonage,

promoter or Manchester M3 2JA
supplier of scheme

Date of publication 19 January 2023

Scheme Reference 64011522

Number (SRN)

Date SRN allocated 19 May 2022

to the scheme

Legislation under Disclosure of Tax Avoidance Schemes (DOTAS)

which this
scheme/promoter
has been named

Statutory Section 455 of the Corporation Tax Act 2010 (CTA)

Provisions on
which the tax
advantage is based

How the scheme is There is usually a pre-existing loan between a

claimed to work – director/shareholder (the ‘scheme user’) and their
summary company. The user signs an ‘option agreement’ with
the company. In return for signing the option
agreement, the company releases the user from
their obligation to repay the loan. The ‘option’ enters
the user into an annuity agreement with the
company, under which the user is required to pay an
annuity to the company for life, if exercised.
However, an ‘early encashment’ mechanism within
the annuity agreement enables the company to
cancel its option rights for a nominal fee. The
company will usually cancel the option so that the
scheme users do not pay the annuity or loan
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repayment. Therefore, the company does not pay

Corporation Tax on the loan.

Judicial rulings HMRC v AML Tax (UK) Ltd [2022] UKFTT 114
relating to the
scheme

AML Tax (UK) Limited – AML Prefunded EBT

Name of scheme AML Prefunded EBT

Name of promoter AML Tax (UK) Limited (AML)

or supplier of
scheme

Address of 1st Floor, Blackfriars House, Parsonage,

promoter or Manchester M3 2JA
supplier of scheme

Date of publication 19 January 2023

Scheme Reference 71821313

Number (SRN)

Date SRN allocated 19 May 2022

to the scheme

Legislation under Disclosure of Tax Avoidance Schemes (DOTAS)

which this
scheme/promoter
has been named

Statutory Section 62 Income Tax (Earnings and Pensions)

Provisions on which Act 2003 (ITEPA)
the tax advantage is
based

How the scheme is An offshore company linked to AML creates and

claimed to work – funds an employee benefit trust (EBT). The
summary offshore company sells its right to nominate a
beneficiary of the EBT to a company that the
scheme users are directors of (the ‘user company’).
The user company nominates the scheme users as
beneficiaries and assigns them the debt that is
owed to the offshore company via the director’s
loan account (DLA); this debt is left outstanding.
The outstanding debt is used to offset other loans
received through the DLA, therefore avoiding
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Income Tax. The company also claims a

Corporation Tax deduction for the amount of this
assigned debt under employee costs.

Judicial rulings HMRC v AML Tax (UK) Ltd [2022] UKFTT 114
relating to the
scheme

AML Tax (UK) Limited – AML Split Contract

Name of scheme AML Split Contract

Name of promoters AML Tax (UK) Limited (AML) / Denmedical UK

or suppliers of Limited
scheme

Address of 1st Floor Blackfriars, Parsonage, Manchester M3

promoters or 2JA (address same for both promoters / suppliers)
suppliers of
scheme

Date of publication 19 January 2023

Scheme Reference 15062269

Number (SRN)

Date SRN allocated 28 July 2022

to the scheme

Legislation under Disclosure of Tax Avoidance Schemes (DOTAS)

which this
scheme/promoter
has been named

Statutory Section 62 Income Tax (Earnings and Pensions) Act

Provisions on 2003 (ITEPA)
which the tax
advantage is based

How the scheme is AML and Denmedical UK Limited promote the same
claimed to work – scheme. A limited company splits the services
summary provided by its director (the ‘scheme user’) into
‘fiduciary services’ and ‘consultancy services’. An
offshore company contracts with the scheme user to
supply their consultancy services to the limited
company via the offshore company. The scheme
user also signs a loan agreement with the offshore
company in their capacity as trustee of a linked
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benefit trust. The scheme user is paid a notional

salary from the limited company for fiduciary
services, a loan from the linked trust and a notional
retainer payment from the offshore company. The
retainer payment and loan are both claimed to
relate to ‘self-employed consultancy services’. The
loan is made without Income Tax or National
Insurance contributions deducted.

Judicial rulings HMRC v AML Tax (UK) Ltd and Denmedical UK Ltd
relating to the [2022] UKFTT 174
scheme

Apricot Umbrella Limited

Details of persons Apricot Umbrella Limited (AUL) / Mr Brian Ash

suspected of promoting (Former director of Apricot Umbrella Limited) /
the scheme, or of being ADYE Ltd (Based in Cyprus) / Giannakis
a connected person, or Fisentzou (Director of ADYE Ltd)
having any other role in
relation to making the
scheme available for
implementation

Addresses of persons Apricot Umbrella Limited: 20 North Lane,

suspected of promoting Canterbury, CT2 7PG / ADYE Ltd: 5-7 G&S
the scheme, or having Court, 4th Floor, Flat/Office 401, 6030,
any other role in Larnaca, Cyprus
relation to making the
scheme available for
implementation

Date of publication 2 August 2023

Legislation under which Finance Act 2022

this scheme/promoter
has been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients or agencies
through AUL and entering into an agreement
where individuals grant ADYE Ltd a right to
enter an Annuity Agreement in exchange for
payments (the ‘Grantee Payments’). The
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individuals receive payment from AUL,

however, tax and National Insurance
contributions (NICs) are only deducted on a
small part of the amount. This is evidenced on
the payslips and figures reported to HMRC. It is
HMRC’s view, that the larger amount, paid
without deduction of tax and NICs was for the
‘Grantee Payments’, but is paid by AUL on
behalf of ADYE Ltd. It is also HMRC’s view that
the ‘Grantee Payments’ were additional
disguised income for the services individuals
provided through AUL, and therefore the entire
payment should be subject to tax and NICs.

Any other information HMRC have previously published Spotlight 60

HMRC considers guidance on agency workers and contractors
relevant to publish employed by umbrella companies. HMRC has
about these schemes now allocated a Scheme Reference number,
49908130, to the arrangements on 02
November 2023 under section 311 Finance Act
2004 ‘Disclosure of Tax Avoidance Schemes’.

Astra Limited

Details of persons Astra Limited (Based in Isle of Man) / David Coyle

suspected of (director of Astra Limited) / TGI Payday Limited
promoting the
scheme, or of
being a connected
person

Addresses of Astra Limited: 6th Floor, Harbour Court, Lord Street,

persons suspected Douglas, Isle of Man, IM1 4LN / TGI Payday
of promoting the Limited: 145 Grimsby Road, Cleethorpes, England,
scheme DN35 7DG

Date of publication 28 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

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How the scheme is The scheme users sign a contract of employment

claimed to work and commercial loan agreement with Astra Limited
based in the Isle of Man. A UK umbrella company
(TGI Payday Limited) then enters into an agreement
for administrative services with Astra Limited for the
provision of the scheme user’s services. TGI
Payday Limited then contract the scheme user’s
services to a UK intermediary/agency. The UK
intermediary/agency then contracts the scheme
user’s services to the end client. The end client pays
the UK intermediary/agency for the scheme user’s
services, who in turn pay TGI Payday Limited.
Following the deduction of a fee, TGI Payday
Limited pay the remaining amount to Astra Limited.
Astra Limited pay a National Minimum
Wage/National Living Wage salary to the scheme
users, which is subjected to deductions of Income
Tax and National Insurance contributions (NICs),
and an additional payment, described as a loan,
pursuant to the loan agreement, which is made
without the deductions of Income Tax or NICs.

Any other HMRC also issued a POTAS Stop Notice to Astra

information HMRC Limited and TGI Payday Limited on 16 July 2024
considers relevant and published details of the arrangements on 14
to publish about November 2024. The Stop Notice requires Astra
these schemes Limited and TGI Payday Limited to stop selling or
promoting the scheme. You can find more details on
List of tax avoidance schemes subject to a stop
notice. Details are listed under Stop notice 40.

B2BTradecard Ltd

Details of persons Promoter: B2BTradecard Ltd (B2B)

suspected of
promoting the
scheme

Addresses of 5a Chorley Business and Technology Centre,

persons suspected Euxton Lane, Chorley, PR7 6TE
of promoting the
scheme

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Date of publication 18 July 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve companies buying

claimed to work ‘advertising’ services from B2B to connect with
other organisations via B2B’s online platform. The
companies claim Corporation Tax deductions for
the amounts spent on B2B advertising. B2B then
return up to 80% of the advertisement spend to
the associated directors or any person chosen by
the company via the provision of prepaid debit
cards without deductions by the company for
Income tax or National Insurance contributions
(NICs). These amounts are described as ‘loyalty
points’ with every 1 point worth £1 to the
individual.

Any other It is HMRC’s view that the redeemed ‘loyalty

information HMRC points’ are disguised remuneration and as such
considers relevant to should be subject to deductions for Income Tax
publish about these and NICs. Furthermore, it is also HMRC’s view
schemes that the advertising amounts paid by the
companies to B2B are not allowable deductions
for Corporation tax purposes.

Back Office Assistance 1 Limited

Details of persons Back Office Assistance 1 Limited (BOA1L)

suspected of
promoting the
scheme

Addresses of 167-169 Great Portland Street, London, W1W 5PF

persons suspected
of promoting the
scheme

Date of publication 10 April 2025

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Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve users providing their

claimed to work services to ‘end users’ as employees of BOA1L.
Employees of BOA1L receive part of their
remuneration as a salary, paid at or close to the
minimum rate permitted under the National
Minimum Wage Act 1998, that is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). However, HMRC suspects
that they also receive a secondary element of their
renumeration without deductions for Income Tax
and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the User’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC has previously published Spotlight 60
these schemes on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC is aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advises
employees of BOA1L to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income. The arrangements target employees in the
healthcare and local council professions.

Back Office Services 1 Limited

Details of persons Back Office Services 1 Limited (BOS1L)

suspected of
promoting the
scheme

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Addresses of 167-169 Great Portland Street, London, W1W 5PF

persons suspected
of promoting the
scheme

Date of publication 10 April 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve users providing their

claimed to work services to ‘end users’ as employees of BOS1L.
Employees of BOS1L receive part of their
remuneration as a salary, paid at or close to the
minimum rate permitted under the National
Minimum Wage Act 1998, that is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). However, HMRC suspects
that they also receive a secondary element of their
renumeration without deductions for Income Tax
and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the User’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC has previously published Spotlight 60
these schemes on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC is aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme and
a non-compliant scheme. HMRC advises
employees of BOS1L to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income. The arrangements target employees in the
healthcare, social care and local authority
professions.

Back Office Systems 1 Limited

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Details of persons Back Office Systems 1 Limited (BOSYSL)

suspected of
promoting the
scheme

Addresses of 7 Bell Yard, Bell Yard, London, England, WC2A

persons suspected 2JR
of promoting the
scheme

Date of publication 1 May 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve scheme users providing

claimed to work their services to end users as employees of
BOSYSL. Employees of BOSYSL receive part of
their remuneration as a salary, paid at or close to
the minimum rate permitted under the National
Minimum Wage Act 1998, that is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). However, HMRC suspect that
employees also receive a secondary element of
remuneration that is not subjected to deductions
for Income Tax and NICs.

Any other HMRC’s view is that both elements of the

information HMRC employee’s pay are earnings from employment
considers relevant and therefore subject to Income Tax and NICs.
to publish about HMRC have previously published Spotlight 60 on
these schemes Disguised remuneration schemes involving agency
workers and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, for
example a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
BOSYSL to familiarise themselves with the
guidance in Spotlight 60 and to satisfy themselves
that the correct amount of tax is being deducted on
their income. The arrangements target
professionals working in the healthcare, social care
and local authority sectors.

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Balance Bay Limited

Details of persons Balance Bay Limited (BBL)

suspected of
promoting the
scheme

Addresses of Office 5272, 321-323 High Road, Romford,

persons suspected England, RM6 6AX
of promoting the
scheme

Date of publication 8 August 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Employees of BBL receive part of their

claimed to work remuneration as a salary, paid at or close to the
minimum rate permitted under the National
Minimum Wage Act 1998, that is subjected to
deductions for income tax and National Insurance
contributions (NICs). However, they also receive a
secondary element of their remuneration without
deductions for Income Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, for example a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of BBL to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

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Balance Bay Services Limited

Details of persons Balance Bay Services Limited (BBSL)

suspected of
promoting the
scheme

Addresses of 7 Bell Yard, London, WC2A 2JR

persons suspected
of promoting the
scheme

Date of publication 7 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide their services to end clients as

claimed to work employees of BBSL. Some employees of BBSL
receive part of their remuneration as a salary, paid
at or close to the minimum rate permitted under the
National Minimum Wage Act 1998 that is subjected
to deductions for Income Tax and National
Insurance contributions (NICs). The employees
also receive a secondary element of their
remuneration without the deduction of Income Tax
and NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant
scheme. HMRC also has reason to suspect that
BBSL targets NHS and Council workers. HMRC
advise employees of BBSL to familiarise
themselves with the guidance and to satisfy

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themselves that the correct amount of tax is being

deducted on their income.

Blizzard Pay Ltd

Details of persons Blizzard Pay Ltd (BPL)

suspected of
promoting the
scheme

Addresses of 20 Wenlock Road, London, N1 7GU

persons suspected
of promoting the
scheme

Date of publication 25 July 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of BPL. Employees receive part of
their BPL remuneration at a rate close to the
National Minimum Wage or National Living Wage
which is subjected to deductions for Income Tax
and National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deduction of Income Tax
or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ pay are employment income, and
considers relevant to therefore subject to Income Tax and NICs. HMRC
publish about these have previously published Spotlight 60 on
schemes disguised remuneration schemes involving agency
workers and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
BPL to familiarise themselves with the guidance

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and to satisfy themselves that the correct amount

of tax is being deducted on their income.

Bluemoore Associates Ltd

Details of persons Bluemoore Associates Ltd (BAL) /Oliver Jenner

suspected of (Sole director of BAL)
promoting the
scheme, or of being a
connected person

Addresses of Bluemoore Associates Ltd: 50 Princes Street,

promoters suspected Ipswich, IP1 1RJ
of promoting the
scheme

Date of publication 28 June 2023

Publication last 1 December 2023

updated

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve users providing their

claimed to work services to end clients through BAL. The users
sign a contract of employment that will pay them
a basic salary at a rate of National Minimum
Wage or National Living Wage which is
subjected to tax and National Insurance
contributions. Scheme users also receive a
second payment. This second payment is paid
by a third-party, or by BAL itself, without tax or
National Insurance contributions being
deducted.

Any other information HMRC have previously published Spotlight 45

HMRC considers and Spotlight 60 guidance on disguised
relevant to publish remuneration schemes involving umbrella
about these schemes companies based on similar arrangements.
HMRC allocated a Scheme Reference number,
69178522, to the arrangements on 12 July 2023
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under section 311 Finance Act 2004 ‘Disclosure

of Tax Avoidance Schemes.’

Bluestar Financial Solutions Limited

Details of persons Bluestar Financial Solutions Limited / Steven Alan

suspected of Carridge (Director of Bluestar Financial Solutions
promoting the Limited)
scheme, or of being a
connected person

Address of Bluestar Financial Solutions Limited, 71-75

promoters suspected Shelton Street, London, WC2H 9JQ
of promoting the
scheme

Date of publication 17 November 2023

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme user enters an employment contract

claimed to work – with Bluestar Financial Solutions Limited who
summary make composite payments to the scheme users
for services provided by the user. The first
element is a salary with tax and National
Insurance contributions (NICs) deducted, and a
secondary element described as a ‘propelled
payment’ with no tax and NICs deducted.

Any other HMRC have previously published Spotlight 60 on

information HMRC disguised remuneration schemes involving
considers relevant to agency workers and contractors employed by
publish about these umbrella companies.
schemes

Buckingham Wealth Ltd

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We have published entries that relate to 2 schemes operated by

Buckingham Wealth Ltd:

scheme 1 – published under Finance Act 2022

scheme 2 – published under Promoters of Tax Avoidance Schemes
regime

Scheme entry 1

Name of promoter or Buckingham Wealth Ltd (BWL) (incorporated in

supplier of scheme Belize) / Minerva Services Ltd (MSL) (incorporated
in Belize)

Address of promoter Buckingham Wealth Ltd (Belize), 1 Orchid Garden

or supplier of Street, Belmopan, Belize / Minerva Services Ltd
scheme (Belize), PO Box 445, Suite 5, Garden City Plaza,
Mountainview Boulevard, Belmopan, Belize

Date of publication 3 May 2023

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Under the Umbrella Remuneration Trust (URT)

claimed to work – arrangements, a scheme user (for example a
summary company or a self-employed person) contributes
to an offshore remuneration trust and claims the
contribution as a deductible Corporation Tax or
Income Tax expense. The money claimed to have
been contributed to the trust is subsequently
transferred, typically via another company, to the
company’s director or back to the self-employed
person. The director claims the funds received this
way are held as ‘loans’ or held in a fiduciary
capacity. HMRC has determined that these
amounts are subject to tax, and recent tribunal
decisions for the corporate users support this.

Any other We have published a document that shows BWL

information HMRC and MSL (the ‘Promoters’) encouraging URT users
considers relevant to to sign a declaration that claims the URT to which
publish about these contributions were made is void, and HMRC must
schemes close its enquiries as they are invalid, and instead
make a ‘replacement’ contribution to a newly
founded ‘Nova’ Trust. HMRC considers this to be
an acknowledgement by the Promoters that the
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URT arrangements do not work. The enquiries

remain valid and HMRC considers that the Nova
Trust arrangements are a continuation of the
arrangements used by the URT, and therefore
subject to tax and NICs. HMRC would encourage
all users of the URT not to enter into Nova without
obtaining independent advice.

Documents which Please find below a link to the page for published
are appropriate to documents, including the document issued by the
publish Promoters to clients – the document contains a
summary of the Nova arrangement and a
question-and-answer section. HMRC do not agree
with the assertions made in this document. We are
publishing it to aid understanding of how Nova is
claimed to work; to demonstrate that the
Promoters do not appear to believe their own tax
avoidance scheme works; and to deter potential
scheme users from trusting the claims made by
these Promoters. Evidence of marketing material
used by tax avoidance promoters and suppliers.

Scheme entry 2

Name of promoter Buckingham Wealth Ltd (incorporated in Belize)

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop
Notice has been
published

Date arrangements 10 November 2023

subject to Stop
Notice published

Date name of 10 November 2023

promoter subject to
Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a stop

notice

Burnsall Pay Ltd

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Details of persons Burnsall Pay Ltd (BURN)

suspected of
promoting the
scheme

Addresses of 26 Bromwich House, 45 Howson Terrace,

persons suspected Richmond Hill, Richmond, TW10 6RU
of promoting the
scheme

Date of publication 19 September 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of BURN, Employees receive part of
their remuneration from BURN at a rate close to
the National Minimum Wage or National Living
Wage which is subjected to deductions for Income
Tax and National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deduction of Income Tax
or NICs, which BURN may suggest relates to the
reimbursement of expenses.

Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant scheme.
HMRC also has reason to suspect that BURN
target council employees and employees in the
health care sector. HMRC advise employees of
BURN to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

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Calculate Limited

Details of persons Calculate Limited

suspected of
promoting the
scheme

Addresses of Dept 3671, 601 International House, 223 Regent

persons suspected Street, London, W1B 2QD
of promoting the
scheme

Date of publication 16 January 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide their services to end clients as

claimed to work employees of Calculate Limited. Some employees
of Calculate Limited receive part of their
remuneration as a salary, paid at or close to the
minimum rate permitted under the National
Minimum Wage act 1998, that is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). They also receive a secondary
element of their remuneration that is not subjected
to deductions for Income Tax and NICs.

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Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax
to publish about and NICs. HMRC has previously published
these schemes Spotlight 60 on disguised remuneration schemes
involving agency workers and contractors employed
by umbrella companies. HMRC is aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme and
a non-compliant scheme. HMRC advise employees
of Calculate Limited to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income. This arrangement appears to target NHS
workers.

Canopaye Limited

Details of persons Canopaye Limited (CL) / Philip Jackson

suspected of (director of Canopaye Limited) / Niall Bradley
promoting the scheme, (previous director of Canopaye Limited)
or of being a
connected person

Addresses of Canopaye Limited, The Charter Building,

promoters suspected Charter Place, Uxbridge, UB8 1JG
of promoting the
scheme

Date of publication 23 February 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve users providing their

claimed to work – services to end clients through CL. The
summary users also sign an agreement that sees the
users grant CL an option on an Annuity
Agreement. The result is the remuneration for
their services is artificially separated into a
salary and payments said to be in return for the
option. No tax or National Insurance
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contributions are deducted in relation to the

payments for the option.

Any other information HMRC have previously published Spotlight 35

HMRC considers on disguised remuneration schemes involving
relevant to publish annuity agreements based on a similar scheme.
about these schemes

Century Umbrella Limited

Details of persons Century Umbrella Limited

suspected of
promoting the
scheme

Addresses of Third Floor, 207 Regent Street, London, W1B 3HH

persons suspected
of promoting the
scheme

Date of publication 7 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Century Umbrella Limited. Century
Umbrella Limited pay scheme users part of their
remuneration as a salary close to or in line with
the National Minimum Wage or National Living
Wage rates, which is subjected to deductions for
Income Tax and National Insurance contributions
(NICs). The scheme users receive the balance of
their remuneration without the deduction of
Income Tax and NICs.

Any other HMRC’s view is that both elements of the scheme

information HMRC users’ pay are employment income, and therefore
considers relevant to subject to Income Tax and NICs. HMRC have
publish about these previously published Spotlight 60 on disguised
schemes remuneration schemes involving agency workers
and contractors employed by umbrella companies.
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HMRC are aware that some umbrella companies

operate more than one scheme, offering a
standard compliant arrangement as well as a non-
compliant scheme. HMRC advise employees of
Century Umbrella Limited to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Charteris Management Ltd

Details of persons 1. Charteris Management Ltd (CML) / 2. Taurus

suspected of Limited (Incorporated Isle of Man) / 3. Howe
promoting the Consultancy Limited (Incorporated Isle of Man) /
scheme, or having 4. Griffith Anderson Limited / 5. Integra
any other role in Resourcing Ltd (Incorporated Malta) / 6. Jeceris
relation to making the Limited / 7. Ombros Solutions Limited
scheme available for
implementation

Addresses of 1. Charteris Management Ltd of Manchester

persons suspected of Business Park, 3000 Aviator Way, Manchester,
promoting the M22 5TG. / 2. Taurus Limited of 3rd floor, Atlantic
scheme, or having House, 4-8 Circular Road, Douglas, Isle of Man,
any other role in IM1 1AG. / 3. Howe Consultancy Limited of 3rd
relation to making the floor, Atlantic House, 4-8 Circular Road, Douglas,
scheme available for Isle of Man, IM1 1AG. / 4. Griffith Anderson
implementation Limited of 7 Bell Yard, London, WC2A 2JR. / 5.
Integra Resourcing Ltd of Block 12, Office M1,
Suite 106, Tigne Place, Tigne Street, Sliema,
SLM3173, Malta. / 6. Jeceris Limited of Solway
House Business Centre, Parkhouse Road,
Kingstown, Carlisle, CA6 4BY. / 7. Ombros
Solutions Limited of 33 Colston Avenue, Bristol,
BS1 4UA.

Date of publication 24 November 2022

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

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How the scheme is The scheme users enter into an employment

claimed to work – contract with CML, providing their services to end
summary clients through CML, sometimes via an agency.
The scheme users may also sign a separate
contract with a second party at the same time.
See entries 2 to 7 of ‘Details of persons
suspected of promoting the scheme, or having
any other role in relation to making the scheme
available for implementation’ for a list of second
parties. CML will invoice the end client or agency
for the work and, after deducting a fee, pay the
scheme user a salary at, or just above the
National Minimum Wage and then pay the
remaining funds to the second party. This is
disguised as an ‘introducer fee’, as CML claim the
second party introduced the scheme user to CML.
The second party, after deducting a fee, then
makes a larger payment to the scheme user,
which may be labelled as a ‘loan’, ‘option’, or
something else. Tax and National Insurance
contributions are not paid on the second payment
to the user.

Any other information CML claim the payment to the second party is an
HMRC considers ‘introducer fee’. This is not the case and these
relevant to publish payments can clearly be seen as the balance of
about these schemes the amount the user raises on the timesheet they
send to CML, most of which is to be paid on to
the user by the second party and the rest retained
by the second party as a fee. Tax and National
Insurance contributions have not been paid on
this second payment to the user. The scheme is
targeted predominantly at physiotherapists,
radiographers, nurses and social workers.

Clear Water Administration Limited

Details of persons Clear Water Administration Limited (CWA)

suspected of
promoting the
scheme

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Addresses of Level One Basecamp, Liverpool, 49 Jamaica

persons suspected Street, Liverpool, L1 0AH
of promoting the
scheme

Date of publication 28 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Employees of CWA receive part of their

claimed to work remuneration as a salary, paid close to the
minimum rate permitted under the National
Minimum Wage Act 1998, that is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). CWA employees also receive
a secondary element of their remuneration without
deductions of Income Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant to salary’, and therefore subject to Income Tax and
publish about these NICs. HMRC have previously published Spotlight
schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of CWA to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

Compliant Pay Ltd

Details of persons Compliant Pay Ltd / Ultimate Planning Ltd

suspected of promoting the
scheme, or having any
other role in relation to
making the scheme

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available for
implementation

Addresses of promoters Ultimate Planning Ltd: 128 City Road,

suspected of promoting the London, EC1V 2NX
scheme and addresses of
those suspected of having
any other role in relation to
making the scheme
available for
implementation

Date of publication 28 June 2023

Legislation under which Finance Act 2022

this scheme/promoter has
been named

How the scheme is claimed The arrangements involve a scheme user

to work – summary providing their services to end clients or
agencies through Compliant Pay Ltd, and
then remuneration for the user’s services is
artificially separated into a salary from
Compliant Pay Ltd and a second larger
payment from Ultimate Planning Ltd. The
second payment, described as a ‘Capital
Payment’, is made without payments for
tax and National Insurance contributions.

Any other information Compliant Pay Ltd went into liquidation on

HMRC considers relevant 25 April 2023. Their trading address prior to
to publish about these entering liquidation was: 128 City Road,
schemes London, EC1V 2NX. HMRC have now
notified Compliant Pay Ltd that a Scheme
Reference Number (SRN 13688608) has
been allocated to the arrangements. You
can find out what this means for you by
reading the DOTAS guidance. HMRC have
previously published Spotlight 60 on
agency workers and contractors employed
by umbrella companies.

Connection Point Ltd

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Details of persons Connection Point Ltd (CPL)

suspected of
promoting the
scheme

Addresses of Dept 4408, 196 High Road, London, N22 8HH

persons suspected
of promoting the
scheme

Date of publication 26 September 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of CPL. Employees receive part of
their CPL remuneration at a rate close to the
National Minimum Wage or National Living Wage
which is subject to deductions for Income Tax and
National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deduction of Income Tax
or NICs.

Any other HMRC’s view is that both elements of pay should

information HMRC be treated as ‘normal income/as the user’s salary’,
considers relevant to and therefore subject to tax and NICs. HMRC
publish about these have previously published Spotlight 60 on
schemes disguised remuneration schemes involving agency
workers and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
CPL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on all of their income.

Consortius Solutions Limited

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Details of persons Consortius Solutions Limited (CSL)

suspected of
promoting the
scheme

Addresses of 128 City Road, London, EC1V 2NX

promoters
suspected of
promoting the
scheme

Date of publication 7 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work – employees of CSL. Employees receive part of their
summary CSL remuneration at a rate close to the National
Minimum Wage or National Living Wage which is
subject to deductions for Income Tax and National
Insurance contributions (NICs). Employees receive
the balance of their remuneration without the
deduction of Income Tax or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate more
than one scheme, such as a standard compliant
scheme and a non-compliant scheme. HMRC also
has reason to suspect that CSL targets Council and
health care sector workers. HMRC’s view is that
both elements of the payment should be treated as
‘normal income/as the user’s salary’, and therefore
subject to Income Tax and NICs. HMRC advise
employees of CSL to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

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Contractor Bureau Limited

We have published 2 entries that relate to a scheme operated by Contractor
Bureau Limited:

entry 1 – published under Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime
(POTAS)

Scheme entry 1

Details of persons Contractor Bureau Limited (CBL) / Emmanuel

suspected of Forkuoh (Director of CBL)
promoting the scheme,
or of being a connected
person

Addresses of persons 16 Upper Woburn place, London, WC1H 0AF

suspected of
promoting the scheme

Date of publication 14 March 2024

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is Scheme Users are employed by CBL and

claimed to work provide services to end clients. Users take part
in a Bonus Arrangement and CBL pay advances
to users on the bonus pot. Users then receive
payment from CBL which consists of 2
elements. The first element is a salary with tax
and National Insurance contributions (NICs)
deducted, and the second element is an
‘advance’ without tax and NICs deducted. CBL
claim that the advances are repaid wholly or
partly, as bonus payments are made at some
time in the future.

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Scheme entry 1

Any other information It is HMRC’s view the salary and advances paid
HMRC considers to employees of CBL should be subject to tax
relevant to publish and NICs. HMRC have previously published
about these schemes Spotlight 60 guidance for agency workers and
contractors employed by umbrella companies.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop Notice
has been published

Date arrangements 14 November 2024

subject to Stop Notice
published

Date name of promoter 8 May 2025

subject to Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a stop

notice

Contractorcare Ltd

Name of promoter Contractorcare Ltd

Date arrangements subject to Stop 2 March 2023

Notice published

Date name of promoter subject to 18 April 2024

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

Countrywide Partners Limited

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Details of persons Countrywide Partners Limited (CPL)

suspected of
promoting the scheme

Addresses of persons Suite 114, 25 Goodlass Road, Liverpool L24

suspected of 9HJ
promoting the scheme

Date of publication 2 August 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is Scheme users enter into employment contracts

claimed to work with CPL. CPL invoice and receive payment
from the end user. CPL retain a fee of 15% of
the gross amount received. CPL pay the
scheme user either a National Minimum Wage
or National Living Wage salary which is taxed
under PAYE. CPL pay the remaining amount in
the form of a loan. This amount is not taxed
under PAYE.

Any other information HMRC previously allocated a Scheme

HMRC considers Reference Number (SRN) to the arrangements
relevant to publish and notified CPL of this. SRN 20980718 was
about these schemes allocated on 18 April 2022. A scheme user may
be required to enter into a Loan agreement and
Bonus, Incentive or Pay Scheme Offer
agreement. The purported loan element that
scheme user’s receive may be described as an
‘ILO Bonus’.

Cube Umbrella Limited

Name of promoter of Cube Umbrella Limited (CUL) / Robert

scheme and Charlesworth (Director of CUL)
connected persons

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Address of promoter Fern Hill Business Centre, Foerster Chambers,

of scheme Todd Street, Bury, Greater Manchester, England,
BL9 5BJ

Date of publication 6 June 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Scheme users sign a contract of employment with

claimed to work Cube Umbrella Limited (CUL). CUL then contracts
with employment agencies for the provision of the
scheme user’s services. The employment
agencies then enter into contracts with end clients
for the provision of the scheme user’s services.
Scheme users are paid for their services by CUL.
The payment made to the scheme users is made
up of 2 elements. The first element is a salary
aspect at a rate around National Minimum
Wage/National Living Wage with Income Tax and
National Insurance contributions (NICs) deducted.
The second element is made without deductions of
Income Tax or NICs.

Any other HMRC have previously published Spotlight 60

information HMRC guidance on agency workers and contractors
considers relevant to employed by umbrella companies. HMRC is aware
publish about these that some umbrella companies operate more than
schemes one scheme, for example, a standard compliant
scheme and a non-compliant scheme. HMRC
advises employees of CUL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Dalespay Ltd

Details of persons Dalespay Ltd (DL) / Austin Merritt (Director of

suspected of DL) / Bestia Holdings Ltd (BHL) (Incorporated in
promoting the scheme, Cyprus) / Giannakis Fysentzou (Director of
or of being a BHL)
connected person, or
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having any other role

in relation to making
the scheme available
for implementation

Addresses of persons Dalespay Ltd: 17 Olav Road, Richmond,

suspected of England, DL10 4PU / Bestia Holdings Ltd: 5-7
promoting the scheme G&S Court, 4th Floor, Flat/Office 401 6030,
or having any other Larnaca, Cyprus
role in relation to
making the scheme
available for
implementation

Date of publication 18 August 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients or agencies through
DL and entering into an agreement where
individuals grant BHL a right to enter an Annuity
Agreement in exchange for payments (the
‘Grantee Payments’). The individuals receive a
payment from DL; however, tax and National
Insurance contributions (NICs) are only
deducted on a small part of the amount. This is
evidenced on the payslips and figures reported
to HMRC. It is HMRC’s view that the larger
amount paid without tax or NICs deducted,
relates to the Grantee Payments, but paid by
DL on behalf of BHL. It is also HMRC’s view that
the Grantee Payments are additional disguised
income for services provided by individuals
through DL, and the entire payment should
therefore be subject to tax and NICs.

Any other information HMRC have previously published Spotlight 60

HMRC considers guidance on agency workers and contractors
relevant to publish employed by umbrella companies.
about these schemes

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Earneze Limited

Details of persons Earneze Limited / William Donald Turner also

suspected of known as William Donald Menzies Turner (Director
promoting the of Earneze Limited)
scheme, or of being
a connected person

Addresses of Earneze Limited, 20-22 Wenlock Road, London,

persons suspected England, N1 7GU
of promoting the
scheme

Date of publication 27 February 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Earneze Limited. The employees
receive part of their remuneration at a rate close to
the National Minimum Wage or National Living
Wage which is subjected to deductions for Income
Tax and National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deduction of Income Tax
or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ payment should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and
contractors employed by umbrella companies.
HMRC are aware that some umbrella companies
operate more than one scheme, such as a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of Earneze
Limited to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income. It

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appears employees within the social work sector

have adopted the use of these arrangements.

Easyway Umbrella Limited

Details of persons Easyway Umbrella Limited

suspected of
promoting the
scheme, or of being a
connected person

Addresses of Innovation House, 39 Mark Road, Hemel

promoters suspected Hempstead Industrial Estate, Hemel Hempstead,
of promoting the HP2 7DN
scheme

Date of publication 27 July 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Easyway Umbrella Limited.
Employees receive part of their Easyway
Umbrella Limited remuneration at a rate close to
the National Minimum Wage or National Living
Wage which is subject to Income Tax and
National Insurance. Employees receive the
balance of their remuneration, disguised as a
loan, credit or other payment, without the
deduction of Income Tax or National Insurance.

Any other HMRC considers the untaxed payments as

information HMRC normal income, and tax and National Insurance
considers relevant to contributions are payable. HMRC have previously
publish about these published information on umbrella companies
schemes offering to increase your take home pay Spotlight
45. HMRC are aware that some umbrella
companies operate more than one scheme, eg a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of Easyway
Umbrella Limited to familiarise themselves with
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the guidance and to satisfy themselves that the

correct amount of tax is being deducted on their
income.

Edge Umbrella Limited

Details of persons Edge Umbrella Limited (EUL) / Darren Harding

suspected of (Director of EUL / Joanna Fysentzou (former
promoting the Director of EUL) / Deposlo Holdings Ltd (based in
scheme, or of being Cyprus) / Giannakis Fisentzou (Director of Deposlo
a connected person Holdings Ltd)

Addresses of Edge Umbrella Limited, 78 York Street, London,

promoters W1H 1DP / Deposlo Holdings Ltd, 15 Linda Court,
suspected of Floor 3, 6051, Lanaka, Cyprus
promoting the
scheme

Date of publication 25 September 2023

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients or agencies through
EUL as their employer. The individuals also enter
an agreement with Deposlo Holdings Ltd where
individuals grant the right to enter an Annuity
Agreement in exchange for payments (the Grantee
Payments). The individuals receive payment from
EUL. However, tax and National Insurance
contributions (NICs) are only deducted on a small
part of the amount. This is evidenced on the
payslips and figures reported to HMRC. It is
HMRC’s view that the larger amount paid without
tax or NICs deducted, is for the Grantee Payments,
but paid by EUL on behalf of Deposlo Holdings Ltd.
It is also HMRC’s view that the Grantee Payments
are additional disguised income for services
provided by individuals through EUL, and the entire
payment should therefore be subject to tax and
NICs.
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Any other HMRC have previously published Spotlight 60

information HMRC guidance on agency workers and contractors
considers relevant employed by umbrella companies. Together
to publish about with HMRC, The Committee of Advertising Practice
these schemes (CAP) Compliance team has been taking market-
wide action about the advertising of tax
arrangements. As part of this work, the Advertising
Standards Authority (ASA) published details of
Edge Umbrella Limited on their website
under ‘Non-compliant online advertisers’.
Misleading claims and omissions have been made
about the tax arrangements offered on the Edge
Umbrella website. This followed on from an
Enforcement Notice jointly issued with CAP that
provided guidance to promoters of tax arrangement
schemes. You can read a copy of an Enforcement
Notice.

Employe Limited

Details of persons Employe Limited (EL) – in Liquidation

suspected of
promoting the
scheme

Addresses of Current address: Floor 2, 10 Wellington Place,

persons suspected Leeds, LS1 4AP / Previous address: 50 Princes
of promoting the Street, Ipswich, IP1 1RJ
scheme

Date of publication 7 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Some employees of EL receive part of their

claimed to work remuneration as a salary, paid at, or close to, the
minimum rate permitted under the National
Minimum Wage Act 1998, and that is subjected to
Income Tax and National Insurance contributions
(NICs). They also receive a secondary element of

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their remuneration without deductions for Income

Tax and NICs.

Any other It is HMRC’s view is that both elements of the

information HMRC payments made to employees of EL should be
considers relevant to subject to Income Tax and NICs. HMRC have
publish about these previously published Spotlight 60 on disguised
schemes remuneration schemes involving agency workers
and contractors employed by umbrella companies.
HMRC are aware that some umbrella companies
operate more than one scheme, such as a
standard compliant scheme and a non-compliant
scheme. EL appears to target NHS and Local
Authority workers. HMRC advise employees of EL
to familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

Employe US Limited

Details of persons Employe US Limited (EUL)

suspected of
promoting the
scheme

Addresses of 7 Bell Yard, London, WC2A 2JR

persons suspected
of promoting the
scheme

Date of publication 10 October 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Employees of EUL receive part of their

claimed to work remuneration as a salary, paid at or close to the
minimum rate permitted under the National
Minimum Wage Act 1998, that is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). EUL employees also receive
a secondary element of their remuneration that is
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not subjected to the deduction of Income Tax

and NICs.

Any other It is HMRC’s view is that both elements of the pay

information HMRC made to employees of EUL should be subject to
considers relevant Income Tax and NICs. HMRC have previously
to publish about published Spotlight 60 on disguised remuneration
these schemes schemes involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant scheme.
HMRC advise employees of EUL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Everest Contracting Limited

Details of persons Everest Contracting Limited / Mr Jack McConnell

suspected of (former Director of Everest Contracting Limited)
promoting the
scheme, or of being a
connected person

Addresses of Blinkbox Business Complex, Western Road, Deal,

persons suspected Kent, CT14 6PJ
of promoting the
scheme

Date of publication 5 September 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients or agencies through
their employer, Everest Contracting Limited. The
individuals receive payment from Everest
Contracting Limited; however, tax and National
Insurance contributions (NICs) are only deducted
on a small part of the amount. This is evidenced
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on the payslips and figures reported to HMRC. It

is HMRC’s view that the larger amount, paid
without tax or NICs deducted, represents
additional disguised income for services provided
by individuals through Everest Contracting
Limited, and the entire payment should therefore
be subject to tax and NICs.

Any other The company changed address on 10 June 2024.

information HMRC Everest Contracting Limited was previously
considers relevant to registered at the address: 39 Norfolk Road,
publish about these Desford, Leicester, CT14 6PJ. HMRC have
schemes previously published Spotlight 60 guidance on
agency workers and contractors employed by
umbrella companies.

Excala Solutions Limited

Details of persons Excala Solutions Limited (ESL)

suspected of
promoting the
scheme

Address of Excala Solutions Limited, 71-75 Shelton Street,

promoters Greater London, WC2H 9JQ
suspected of
promoting the
scheme

Date of publication 17 November 2023

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme user enters an employment contract

claimed to work with ESL. ESL then makes a single payment to the
scheme user, but this is artificially separated into 2
elements. The first element is a salary paid at or
around National Minimum Wage or National Living
Wage with tax and National Insurance
contributions (NICs) deducted. The secondary

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element is described as a ‘propelled payment’ with

no tax and NICs deducted.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income’/’as the user’s
considers relevant salary’, and therefore subject to tax and NICs.
to publish about HMRC have previously published Spotlight
these schemes 60 guidance on disguised remuneration schemes
involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate
more than one scheme, eg a standard compliant
scheme and a non-compliant scheme. HMRC
advise employees of ESL to familiarise themselves
with the guidance and to satisfy themselves that
the correct amount of tax is being deducted on
their income.

Expertise Solutions Limited

Details of persons Expertise Solutions Limited

suspected of
promoting the
scheme

Addresses of (Former address) 71-75 Shelton Street, Covent

persons suspected Garden, London, WC2H 9JQ
of promoting the
scheme

Date of publication 3 April 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide their services to end clients as

claimed to work employees of Expertise Solutions Limited. Some
employees of Expertise Solutions Limited receive
their remuneration made up of two elements. The
first is a salary, paid at or close to the minimum
rate permitted under the Minimum Wage Act 1998
which is subjected to Income Tax and National
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Insurance contributions (NICs). HMRC suspects

that employees also receive a secondary element
of remuneration in another form and which is not
subjected to Income Tax and NICs.

Any other HMRC’s view is that both elements of pay should

information HMRC be treated as ‘normal income/as the user’s salary’,
considers relevant and therefore subject to Income Tax and NICs.
to publish about HMRC have previously published Spotlight 60 on
these schemes disguised remuneration schemes involving agency
workers and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
Expertise Solutions Limited to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on all of their income. HMRC suspects
that the arrangements are targeted at NHS
workers.

Fast Payroll UK Ltd

Details of persons Fast Payroll UK Ltd (FPUK) – trading as Fastpay /

suspected of Kieran Elliott (Director of FPUK)
promoting the
scheme, or of being
a connected person

Addresses of 167-169 Great Portland Street, London, W1W 5PF

persons suspected
of promoting the
scheme

Date of publication 22 August 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve users providing their

claimed to work services to end clients as employees of FPUK. The
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users sign an employment contract with FPUK that

will pay them a basic salary, of at least the rate of
National Minimum Wage or National Living Wage,
which is subject to deductions for Income Tax and
National Insurance contributions (NICs). Scheme
users also receive an additional amount (combined
with the basic salary as a single payment) referred
to as a ‘withdrawal amount’, which is paid to them
without the deduction of Income Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax
to publish about and NICs. In most cases, the user’s salary is paid
these schemes at the minimum rate permitted under the National
Minimum Wage Act 1998. HMRC have previously
published Spotlight 60 on disguised remuneration
schemes involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate more
than one scheme, such as a standard compliant
scheme and a non-compliant
scheme. HMRC advise employees of FPUK to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

1st Choice Umbrella Ltd

Name of promoters 1st Choice Umbrella Ltd and

Omni Contractors PCC Limited

Date arrangements subject to Stop 12 September 2024

Notice published

Date name of promoter subject to 12 September 2024

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

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First Paye Consultants Limited

Details of persons First Paye Consultants Limited (FPCL)

suspected of
promoting the
scheme

Addresses of Former address: 20 Chapel Street, Liverpool, L3

promoters suspected 9AG
of promoting the
scheme

Date of publication 5 December 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work – employees of FPCL. Employees receive part of
summary their FPCL remuneration at a rate close to the
National Minimum Wage or National Living Wage
which is subjected to Income Tax and National
Insurance contributions (NICs). Employees
receive the balance of their remuneration without
the deduction of Income Tax or NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant to salary’, and therefore subject to Income Tax and
publish about these NICs. HMRC have previously published Spotlight
schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of FPCL to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

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Flex Payroll and Accounting Services Ltd

We have published 2 entries that relate to a scheme operated by Flex
Payroll and Accounting Services Ltd:

entry 1 – published under Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Name of scheme FlexPAS Advance payment

Name of promoter of Flex Payroll and Accounting Services Ltd (Flex

scheme and PAS) / Russell Lee Forshaw (former Director of
connected persons Flex PAS)

Address of promoter Flex Payroll and Accounting Services Ltd,

of scheme Stapeley House, London Road, Stapeley,
Nantwich, England, CW5 7JW

Date of publication 1 February 2024

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is Flex PAS enters into a contract of employment

claimed to work with scheme users. The scheme users provide
their services to the ‘end client’ and Flex
PAS then invoice the end client for those
services. Flex PAS pays an amount to the
scheme users equivalent to the National
Minimum Wage or National Living Wage with
Income Tax and National Insurance contributions
(NICs) deducted. Flex PAS also makes a second
payment to the scheme user, described as an
‘advance payment’, with no Income Tax
and NICs deducted.

Any other information HMRC has previously published Spotlight 60

HMRC considers about the tax avoidance used by some umbrella
relevant to publish companies. HMRC is aware that some umbrella
about these schemes companies operate more than one scheme, for
example a standard compliant scheme and a
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non-compliant scheme. The Flex PAS website

advertises its services to Doctors, Nurses and
Social Workers in the public sector.
HMRC advises employees of Flex PAS to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax
is being deducted on their income.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop
Notice has been
published

Date arrangements 6 March 2025

subject to Stop Notice
published

Date name of 6 March 2025

promoter subject to
Stop Notice published

POTAS publication List of tax avoidance schemes subject to a stop

notice

Focus Contractor Limited

Name of promoter Focus Contractor Limited

Legislation under which this Stop Promoters of Tax Avoidance

Notice has been published Schemes (POTAS)

Date arrangements subject to Stop 13 April 2023

Notice published

Date publication was last updated 7 June 2023

Date name of promoter subject to Stop 12 October 2023

Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

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GL Premium Ltd

Details of persons GL Premium Ltd (GLPL)

suspected of
promoting the
scheme

Addresses of 7 Bell Yard, London, WC2A 2JR

persons suspected
of promoting the
scheme

Date of publication 3 October 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients, via employment
agencies where applicable, as employees of
GLPL. GLPL declare a portion of the employees’
earnings through Pay As You Earn (PAYE) and
deduct Income Tax and National Insurance
contributions (NICs). The balance of the
employees’ earnings, which may be described as
‘Retained Profit’ on the payslips issued by GLPL is
paid without the deduction of Income Tax and
NICs.

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Any other It is HMRC’s view that the ‘Retained Profit’

information HMRC payments made by GLPL to their employees
considers relevant to should be subject to Income Tax and NICs. HMRC
publish about these have previously published Spotlight 60 guidance
schemes on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, for example, a standard compliant
scheme and a non-compliant scheme. HMRC
advise employees of GLPL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Goldfish Umbrella Limited

We have published 2 entries that relate to a scheme operated by Goldfish
Umbrella Limited:

entry 1 – published under Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Name of scheme Goldfish Umbrella Limited

Details of persons Goldfish Umbrella Limited (GUL)

suspected of
promoting the
scheme

Address of persons Kemp House, 152-160 City Road, London, EC1V

suspected of 2NX
promoting the
scheme

Date of publication 16 May 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named
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How the scheme is Scheme users enter into a contract of employment

claimed to work – with GUL, providing their services to end clients.
summary GUL invoice the end clients for the work and, after
retaining a portion of that invoiced amount, GUL
will make a single payment to the scheme users
made up of 2 elements. The first element is salary
made at National Minimum Wage/National Living
Wage with Income Tax and National Insurance
contributions (NICs) deducted. The second
element is described as an ‘Advance Payment’
and is made without Income Tax and NICs
deducted. The total payment is more than the
scheme users would have received if they were
paid their salary with Income Tax and NICs
correctly deducted on the full amount.

Any other HMRC have previously published a Spotlight on

information HMRC agency workers and contractors employed by
considers relevant to umbrella companies Spotlight 60. HMRC are
publish about these aware that some umbrella companies operate
schemes more than one scheme, such as a standard
compliant scheme and a non-compliant
scheme. HMRC advise employees of GUL to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop
Notice has been
published

Date arrangements 12 September 2024

subject to Stop
Notice published

Date name of 14 November 2024

promoter subject to
Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a stop

notice

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Greenlight Payroll Services Limited

Details of persons Greenlight Payroll Services Limited (GPS) /

suspected of Robert Dixey (Director of GPS) / Greenlight
promoting the Payroll Operations Ltd (in liquidation) / Dynasty
scheme, or of being a Payroll Solutions Ltd
connected person or
having any other role
in relation to making
the scheme available
for implementation

Addresses of Greenlight Payroll Services Limited, 128 City

promoters suspected Road, London, EC1V 2NX / Greenlight Payroll
of promoting the Operations Ltd (in liquidation), Wolverhampton
scheme, or having Science Park, Wolverhampton, WV10 9TG /
any other role in Dynasty Payroll Solutions Ltd, International
relation to making the House, Admirals Way, London, E14 9XL
scheme available for
implementation

Date of publication 28 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve users providing their

claimed to work services to end clients through GPS. The users
sign a contract of employment that will pay them
a basic salary at a rate close to the National
Minimum Wage or National Living Wage. GPS
makes a single payment to the user comprising
this salary which is subjected to deductions for
Income Tax and National Insurance contributions
(NICs) and an additional amount (described as a
‘withdrawal’) which is not subjected to deductions
for Income Tax or NICs. Greenlight Payroll
Operations Ltd has a role in relation to making
the arrangements available for implementation by
handling the scheme users PAYE and RTI
submissions and by issuing documentation to
users. Dynasty Payroll Solutions Ltd has made
significant payments to GPS in respect of users
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of the arrangements and HMRC suspect it has a

role in relation to making the arrangements
available for implementation.

Any other information HMRC’s view is that both elements of the

HMRC considers payment should be treated as ‘normal income/the
relevant to publish user’s salary’ and therefore, subject to Income
about these schemes Tax and NICs. HMRC also has reason to suspect
that GPS target healthcare sector, NHS and
Council employees. HMRC have previously
published Spotlight 60 on disguised remuneration
schemes involving agency workers and
contractors employed by umbrella companies.
HMRC are aware that some umbrella companies
operate more than one scheme, such as a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of GPS to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax
is being deducted on their income.

Hamilton Bradbury Ltd

Name of promoter Hamilton Bradbury Ltd (HBL) (registered in the UK)

or supplier of
scheme

Addresses of Hamilton Bradbury Ltd, Pacific House, Relay Point,

promoters Wilnecote, Tamworth, Staffordshire, B77 5PA
suspected of
promoting the
scheme

Date of publication 25 September 2023

Scheme Reference 81003536

Number (SRN)

Date SRN allocated 28 February 2023

to the scheme

Legislation under Disclosure of Tax Avoidance Schemes (DOTAS)

which this

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scheme/promoter
has been named

Statutory Section 62 Income Tax (Earnings and Pensions) Act

Provisions on 2003 (ITEPA)
which the tax
advantage is based

How the scheme is Scheme users sign a contract of employment and

claimed to work – Loan Agreement with a company based in the Isle of
summary Man, Hamilton Bradbury Consulting Ltd (HBC). HBC
then enters into a contract with HBL, a UK umbrella
company for the provision of the scheme user’s
services. HBL then contracts the scheme user’s
services to a UK intermediary/agency. The UK
intermediary/agency then contracts the scheme
user’s services to the end client. The end client pays
the UK intermediary/agency for the scheme user’s
services, who in turn pay HBL. Following the
deduction of a fee, HBL pay the remaining amount to
HBC. HBC pays a National Minimum Wage/National
Living Wage salary to the scheme user and a
payment, described as a loan, pursuant to the Loan
Agreement, which is made without deductions of
Income Tax or National Insurance contributions.

Judicial rulings HMRC v Hamilton Bradbury Limited (in liquidation)

relating to the UKFTT 99
scheme

Hive Umbrella Ltd

Name of promoter or supplier of Hive Umbrella Ltd

scheme

Legislation under which this Stop Promoters of Tax Avoidance

Notice has been published Schemes (POTAS)

Date arrangements subject to Stop 10 November 2023

Notice published

Date name of promoter subject to Stop 10 November 2023

Notice published

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POTAS publication List of tax avoidance schemes

subject to a stop notice

Imace Limited

Details of persons Imace Limited

suspected of
promoting the
scheme, or of being
a connected person

Addresses of 58 Office 565, 58 Peregrine Road, Hainault, Ilford,

persons suspected Essex, IG6 3SZ
of promoting the
scheme

Date of publication 20 February 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Imace Limited. Employees receive
part of their Imace Limited remuneration at a rate
close to the National Minimum Wage or National
Living Wage which is subject to deductions for
Income Tax and National Insurance contributions
(NICs). Employees receive balance of their
remuneration, disguised as another payment,
without the deductions of Income Tax and NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and
contractors employed by umbrella companies.
HMRC suspects the arrangement is targeted at
NHS and Council workers. HMRC are aware that
some umbrella companies operate more than one
scheme, such as a standard compliant scheme
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and a non-compliant scheme. HMRC advise

employees of Imace Limited to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Infrapro Consulting Limited

Details of persons Infrapro Consulting Limited (ICL)

suspected of
promoting the
scheme

Address of person 4 Admiral Way, Doxford International Business

suspected of Park, Sunderland, United Kingdom, SR3 3XW
promoting the
scheme

Date of publication 26 September 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Scheme users sign a contract of employment with

claimed to work ICL. ICL then sign contracts with employment
agencies for the provision of the scheme users’
services. Scheme users carry out services for end
clients and are paid for their services by ICL. The
payment made to the scheme users is made up of
2 elements. The first element is a salary aspect at
a rate around the National Minimum Wage/National
Living Wage with Income Tax and National
Insurance contributions (NICs) deducted. The
second element is paid to scheme users without
deductions of Income Tax or NICs.

Any other HMRC have previously published Spotlight 60

information HMRC guidance on agency workers and contractors
considers relevant employed by umbrella companies. HMRC is aware
to publish about that some umbrella Companies operate more than
these schemes one scheme, for example, a standard compliant
scheme and a non-compliant
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scheme. HMRC advises employees of ICL to

familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

Integra Resourcing Limited

Name of promoter Integra Resourcing Ltd – registered in Malta (IRL) /

or supplier of Target Umbrella Ltd – registered in the UK (TUL)
scheme

Address of Integra Resourcing Limited, Block 12 Office M1

promoter or supplier Suite 106, Tigne Place, Tigne Street, Sliema,
of scheme Malta, SLM 7173 / Target Umbrella Limited, 6
Margaret Street, Newry, Northern Ireland, BT34
1DF

Date of publication 23 February 2023

Scheme Reference 79326711

Number (SRN)

Date SRN allocated 12 August 2022

to the scheme

Legislation under Disclosure of Tax Avoidance Schemes (DOTAS)

which this
scheme/promoter
has been named

Statutory Provisions Section 62 Income Tax (Earnings and Pensions)

on which the tax Act 2003 (ITEPA)
advantage is based

How the scheme is Users sign separate employment contracts with

claimed to work – IRL and TUL. Users also sign an ‘Overarching
summary Agreement’ with IRL to provide ‘loans’ to the user.
TUL sign a contract for services with the agency or
the end client to provide the services of the user.
TUL then invoices the end client for the work
undertaken by the user. TUL pay users a salary in
line with the National Minimum Wage Act for time
worked and pays the remaining amount to IRL. IRL
then pays the user a second nominal salary, per
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payroll run, usually below £10, and a larger

amount, described as a ‘loan’. The ‘loan’ amount is
not taxed.

Innovate Limited

Details of persons Innovate Limited (IL) – Registered in the Isle of Man

suspected of (in liquidation) / Jolene Cowell (Director of IL) /
promoting the James Paul McAllister (Director of IL) / Frank
scheme, or of being Umbrella Limited (FUL) (in liquidation) / Contractor
a connected person Corner Accounting Limited (CCA) (in liquidation)

Addresses of Innovate Limited (in liquidation), Previous registered

promoters office: 6th Floor, Harbour Court, Lord Street,
suspected of Douglas, Isle of Man, IM1 LN (Registered office
promoting the from 5 November 2019 to 19 January 2024) / Frank
scheme Umbrella Limited - (In Liquidation) Previous
Registered Office: 23 Chantry Lane, Grimsby, NE
Lincolnshire, DN31 2LP (Registered office from 15
November 2020 to 17 January 2024) / Contractor
Corner Accounting Limited (In Liquidation) Previous
registered office: Suite 1, Plymouth House,
Plymouth Road, Blackpool, FY3 7JS (Registered
office from 18 May 2021 to 26 April 2023)

Date of publication 5 September 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme users sign a contract of employment

claimed to work and commercial loan agreement with IL, based in
the Isle of Man. IL then enters into a contract with
FUL and CCA (the ‘UK umbrella companies’), for
the scheme user’s services. The UK umbrella
companies then contracts the scheme user’s
services to a UK intermediary/agency. The UK
intermediary/agency then contracts the scheme
user’s services to the end client. The end client
pays the UK intermediary/agency for the scheme
user’s services, who in turn pay the UK umbrella
companies. The UK umbrella companies pay the full
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amount received to IL, who then pay a fee to the UK

umbrella companies. IL then pays a National
Minimum Wage/National Living Wage salary to the
scheme users with Income Tax and National
Insurance contributions (NICs) deducted, and a
payment, described as a loan and made pursuant to
the loan agreement, without deductions of Income
Tax and NICs.

Any other HMRC’s view is that these payments are actually no

information HMRC different to normal income, and tax and National
considers relevant Insurance contributions are payable. HMRC have
to publish about previously published information about the tax
these schemes avoidance arrangements used by some umbrella
companies Spotlight 60. HMRC are aware that
some umbrella companies operate more than one
scheme, such as a standard compliant scheme and
a non-compliant scheme. HMRC advise employees
of IL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount of
tax is being deducted on their income.

Intu Solutions Limited

Details of persons Intu Solutions Limited (ISL)

suspected of
promoting the
scheme

Addresses of 71-75 Shelton Street, Covent Garden, London,

persons suspected WC2H 9JQ
of promoting the
scheme

Date of publication 21 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals (scheme users) provide their services to

claimed to work end clients as employees of ISL. ISL then makes a
single payment to the scheme users for their
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services, but this is artificially separated into 2

elements. The first element is a salary paid at, or
around, the rate of National Minimum Wage or
National Living Wage with Income Tax and National
Insurance contributions (NICs) deducted. The
second element is described as a ‘propelled
payment’ and paid without deductions for Income
Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme and
a non-compliant scheme. The ISL website
specifically mention the sectors they cover include
Healthcare, Income Tax consultants and Engineers
working in the North Sea. HMRC advise employees
of ISL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

IP Global Consulting Ltd

Details of persons IP Global Consulting Ltd (IPG)

suspected of
promoting the scheme

Addresses of Registered office: 63-66 Hatton Garden, London,

promoters suspected EC1N 8LE / Trading address: 54 St. James
of promoting the Street, Liverpool, L1 0AB
scheme

Date of publication 9 August 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

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How the scheme is IPG invoices a recruitment agency for the

claimed to work – services provided by a scheme user. On receipt
summary of payment from the recruitment agency, IPG
pays a National Minimum Wage amount to the
user with tax and National Insurance
contributions (NICs) deducted. IPG also makes a
second payment to the user, described as an
‘advance’, without tax or NICs deducted.

Jigsaw Payment Solutions Limited

Details of persons Jigsaw Payment Solutions Limited (JPSL) trading

suspected of as Jigsaw Pay
promoting the
scheme

Addresses of 2a Connaught Avenue, London, E4 7AA

persons suspected
of promoting the
scheme

Date of publication 21 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve users providing their

claimed to work services to end clients as employees of JPSL.
Employees receive a basic salary as part of their
remuneration from JPSL at a rate close to or
around the National Minimum Wage or National
Living Wage salary which is subject to Income Tax
and National Insurance contributions (NICs)
deductions. JPSL make a single payment to the
users comprising of the basic salary and the
balance of their remuneration. The latter part of the
payment is without the deduction of Income Tax
or NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
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to publish about NICs. HMRC have previously published Spotlight

these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme and
a non-compliant scheme. HMRC advise employees
of JPSL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

Just Standard Limited

Details of persons Just Standard Limited (JSL)

suspected of
promoting the
scheme

Addresses of 71-75, Shelton Street, London, WC2H 9JQ

persons suspected
of promoting the
scheme

Date of publication 3 October 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of JSL. Employees receive part of their
JSL remuneration at a rate close to the National
Minimum Wage or National Living Wage which is
subject to deductions for Income Tax and National
Insurance contributions (NICs). Employees
receive the balance of their remuneration without
the deduction of Income Tax or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant to income/as the user’s salary’, and therefore subject
publish about these to Income Tax and NICs. HMRC have previously
schemes published Spotlight 60 on disguised remuneration
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schemes involving agency workers and

contractors employed by umbrella companies.
HMRC are aware that some umbrella companies
operate more than one scheme, for example, a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of JSL to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

K & B Umbrella Ltd

Details of persons K & B Umbrella Ltd (also known as Knight and

suspected of Bishop Services, and Knight & Bishop, company
promoting the number 14581885)
scheme

Addresses of International House, 307 Cotton Exchange, Old

persons suspected Hall Street, Liverpool, United Kingdom, L3 9LQ
of promoting the
scheme

Date of publication 3 April 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of K & B Umbrella Ltd. Employees
receive part of their remuneration at a rate close to
the National Minimum Wage or National Living
Wage which is subjected to deductions for Income
Tax and National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deduction of Income Tax
or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ pay should be treated as ‘normal
considers relevant to income/as the user’s salary’, and therefore subject
publish about these to Income Tax and NICs. HMRC have previously
schemes published Spotlight 60 on disguised remuneration
[Link] 80/157
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schemes involving agency workers and

contractors employed by umbrella companies.
HMRC are aware that some umbrella companies
operate more than one scheme, such as a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of K & B
Umbrella Ltd to familiarise themselves with the
guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

Langan Scott and Co Ltd

Details of persons Langan Scott and Co Ltd (LSCL)

suspected of
promoting the
scheme

Addresses of persons 167-169 Great Portland Street, 5th Floor,

suspected of London, England, W1W 5PF
promoting the
scheme

Date of publication 19 September 2024

Information updated 7 November 2024

Scheme Reference 09322856

Number (SRN)

Date SRN allocated to 5 September 2024

the scheme

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients as employees of
LSCL. Employees receive part of their
remuneration from LSCL through Pay As You
Earn (PAYE) with Income Tax and National
Insurance contributions (NICs) deducted.
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Employees receive the balance of their

remuneration from LSCL, which may be
described as ‘Retained Profit’ on pay slips,
without the deduction of Income Tax and NICs.

Any other information The SRN 09322856 was allocated to the

HMRC considers arrangements on 5 September 2024. It is
relevant to publish HMRC’s view that the ‘Retained Profit’ payments
about these schemes made by LSCL to their employees should be
subject to Income Tax and NICs. HMRC have
previously published Spotlight 60 guidance on
disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme: for example, a standard compliant
scheme and a non-compliant scheme. HMRC
advise employees of LSCL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is
being deducted on their income.

Level Up Associates Limited

Details of persons Level Up Associates Limited (LUA)

suspected of
promoting the
scheme

Addresses of 7 Bell Yard, London, WC2A 2JR

persons suspected
of promoting the
scheme

Date of publication 27 February 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of LUA. Some employees of LUA
receive their remuneration made up of two
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elements. The first is a salary, paid at or close to

the minimum rate permitted under the National
Minimum Wage Act 1998 which is subject to
deductions for Income Tax and National Insurance
contributions (NICs). Employees also receive a
secondary element of their remuneration without
deductions of Income Tax and NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and contractors
employed by umbrella companies. HMRC
suspects that the arrangement is mainly targeted
at local authority workers. HMRC are aware that
some umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of LUA to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

LWI Services Limited

Name of promoter LWI Services Limited

Address of promoter Rodus Building 4th Floor, Road Reef PO

Box 765, Road Town, Tortola, British
Virgin Islands

Date arrangements subject to 17 October 2024

Stop Notice published

Date name of promoter subject 17 October 2024

to Stop Notice published

POTAS publication List of tax avoidance schemes subject to

a stop notice

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Masterstroke Solutions Limited

Details of persons Masterstroke Solutions Limited

suspected of
promoting the
scheme

Addresses of 128 City Road, London, EC1V 2NX

persons suspected
of promoting the
scheme

Date of publication 16 January 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Masterstroke Solutions Limited.
Employees receive part of their Masterstroke
Solutions Limited remuneration at a rate close to the
National Minimum Wage or National Living Wage
which is subject to deductions for Income Tax and
National Insurance contributions (NICs). Employees
receive the balance of their remuneration without
the deduction of Income Tax or NICs.

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Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and contractors
employed by umbrella companies. HMRC suspect
that Masterstroke Solutions Limited targets
healthcare workers. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme and
a non-compliant scheme. HMRC advise employees
of Masterstroke Solutions Limited to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Medbridge Ltd

Details of persons Medbridge Ltd

suspected of
promoting the
scheme

Addresses of Former Address: Suite 2a, Blackthorn House, St

persons suspected Pauls Square, Birmingham, B3 1RL
of promoting the
scheme

Date of publication 30 January 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Medbridge Ltd. Some employees of
Medbridge Ltd receive part of their remuneration
as a salary, paid at or close to the minimum rate
permitted under the National Minimum Wage Act
1998 (NMW), that is subject to deductions for
Income Tax and National Insurance contributions
(NICs). The employees also receive a second
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element of their remuneration which is made

without deduction of Income Tax and NICs.

Any other HMRC’s view is that both elements of pay should

information HMRC be treated as ‘normal income/as the user’s salary’,
considers relevant and therefore subject to Income Tax and NICs.
to publish about HMRC have previously published Spotlight 60 on
these schemes disguised remuneration schemes involving agency
workers and contractors employed by umbrella
companies. Medbridge Ltd appears to target
healthcare and local authority workers. HMRC are
aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant scheme.
HMRC advise employees of Medbridge Ltd to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

Miwsa Limited

Details of persons Miwsa Limited / BHD Consultants Ltd (BHD) / HRG

suspected of Consulting Ltd (HRG) / HWX Consulting Ltd (HWX)
promoting the / JBatts Ltd (JBL) / JJDM Consulting Ltd (JJDM)
scheme, or having
any other role in
relation to making
the scheme
available for
implementation

Addresses of Miwsa Limited: Suite 03, 5 Wandsworth Road,

persons suspected Perivale, London, UB6 7JD / BHD Consultants Ltd:
of promoting the 28 Newcombe Court, Burgess Springs,
scheme, or having Chelmsford, Essex CM1 1QN / HRG Consulting
any other role in Ltd: 30 Jameston, Bracknell, RG12 7WZ / HWX
relation to making Consulting Ltd: 14 Ravensbury Avenue, Morden,
the scheme SM4 6ET / JBatts Ltd: 14 Ravensbury Avenue,
available for Morden, SM4 6ET / JJDM Consulting Ltd: 20-22
implementation Wenlock Road, London, N1 7GU

Date of publication 19 September 2024

Information updated 1 May 2025

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Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve users providing their

claimed to work services to end clients as employees of Miwsa
Limited. The users get paid a basic salary at or
around the rate of National Minimum Wage or
National Living Wage with deductions for Income
Tax and National Insurance contributions (NICs).
However, scheme users also receive a secondary
payment without deductions for Income Tax and
NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, for example, a standard compliant
scheme and a non-compliant
scheme. HMRC advise employees of Miwsa
Limited to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income. HMRC
suspects that BHD, HRG, HWX, JBL, JJDM have a
role in relation to making available the scheme
promoted by ML by acting as marketing and sales
agents for ML and by introducing workers to ML in
accordance with a brokerage agreement. HMRC
advise recruitment agents and others contacted by
these companies on behalf of umbrella companies
to familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax
will be deducted from any income paid by the
umbrella companies.

Miwsa Management Ltd

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Details of persons Miwsa Management Ltd (MML)

suspected of
promoting the
scheme

Addresses of 7 Bell Yard, London, WC2A 2JR

persons suspected
of promoting the
scheme

Date of publication 3 October 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve scheme users providing

claimed to work their services to end clients as employees of MML.
The scheme users are paid a basic salary at or
around the rate of National Minimum Wage or
National Living Wage, which is subject to
deductions for Income Tax and National Insurance
contributions (NICs). Scheme users also receive
amounts in addition to the basic salary without
deductions for Income Tax and NICs.

Any other HMRC’s view is that both elements of pay should

information HMRC be treated as ‘normal income/as the user’s salary’,
considers relevant to and therefore subject to Income Tax and
publish about these NICs. HMRC have previously published Spotlight
schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of MML to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

MLG Pay Limited

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We have published 2 entries that relate to one scheme operated by MLG

Pay Ltd:

entry 1 – published under the Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Details of persons MLG Pay Limited (MLG)

suspected of
promoting the
scheme

Addresses of Suite 101, 89 High Street, Sidcup, DA14 6DW

persons suspected
of promoting the
scheme

Date of publication 21 December 2023

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme user’s total remuneration for their
claimed to work contracts with MLG is artificially separated into 2
elements. The first element is a salary with Income
Tax and National Insurance contributions (NICs)
deducted. The second element is paid without
deduction of Income Tax and NICs by MLG. This
second element is claimed to be for an option
grant or sometimes referred to as ‘benefits in kind’.

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Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and is therefore subject to tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of MLG to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop Notice
has been published

Date arrangements 18 April 2024

subject to Stop Notice
published

Date name of 6 February 2025

promoter subject to
Stop Notice published

POTAS publication List of tax avoidance schemes subject to a stop

notice

Mountain View Admin Limited

Details of persons Mountain View Admin Limited / Mountain View

suspected of Administration Limited / Mr John O’Malley
promoting the (Director of Mountain View Administration Limited)
scheme, or of being
a connected person

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Addresses of Mountain View Admin Limited, 71-75 Shelton

persons suspected Street, Covent Garden, London. WC2H 9JQ
of promoting the (registered office) / Mountain View Administration
scheme Limited, Gatcombe House, Copnor Road,
Portsmouth, Hampshire, PO3 5EJ (registered
office)

Date of publication 6 June 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme users enter an employment contract

claimed to work with Mountain View Administration Limited and
provides their services to an end client. Mountain
View Admin Limited then pays the scheme users
for their services. The payment is artificially
separated into 2 elements. The first element is a
salary paid with Income Tax and National
Insurance contributions (NICs) deducted. The
second element, described as a ‘projected
payment’ with no deduction of Income Tax and
NICs. This second element had been previously
described as a ‘Propelled payment’ also made with
no deduction of Income Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant to salary’, and therefore subject to Income Tax and
publish about these NICs. HMRC have previously published Spotlight
schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of Mountain View Admin Ltd and
Mountain View Administration Limited to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on all of their income.

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New Mill Resourcing Ltd

Details of persons New Mill Resourcing Ltd / Suresh Kumar (Director

suspected of of New Mill Resourcing Ltd)
promoting the
scheme, or of being
a connected person

Addresses of 85 Great Portland Street, London, England, W1W

persons suspected 7LT
of promoting the
scheme

Date of publication 18 July 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients through New Mill
Resourcing Ltd. The individuals receive 2
payments from New Mill Resourcing Ltd on the
same date. The first payment is salary paid at a
rate close to the minimum permitted under the
National Minimum Wage Act 1998, with Income
Tax and National Insurance contributions (NICs)
deducted. The second payment, described as a
‘Withdrawal amount’ against the individuals
company incentive plan report, is paid without the
deduction of Income Tax and NICs. It is HMRC’s
position that the whole payment is actually income
received in respect of the individual’s services
provided through New Mill Resourcing Ltd and
Income tax and NICs are payable on it.

Any other HMRC have previously published a Spotlight on

information HMRC agency workers and contractors employed by
considers relevant to umbrella companies Spotlight 60. HMRC are
publish about these aware that some umbrella companies operate
schemes more than one scheme, such as a standard
compliant scheme and a non-compliant scheme.
HMRC advise scheme users to familiarise
themselves with the guidance and to satisfy
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themselves that the correct amount of tax is being

deducted on their income.

Odyssey Payroll Limited

Details of persons Odyssey Payroll Limited (OPL) / Jonathan Malyon

suspected of (Director of Odyssey Payroll Limited)
promoting the
scheme, or of being
a connected person

Addresses of 28 Baddow Road, Chelmsford, England, CM2 0DG

persons suspected
of promoting the
scheme

Date of publication 5 September 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Scheme users sign a contract of employment with

claimed to work OPL. OPL enters into contracts with employment
agencies to provide the services of OPL scheme
users. The agencies enter into contracts with end
clients for the provision of scheme users’ services.
Scheme users are paid for their services by OPL.
Payment to users include a part which relates to
salary at a rate around National Minimum
Wage/National Living Wage, which is subject to
Income Tax and National Insurance contributions
(NICs) deductions. The remainder of the payment
is without Income Tax or NICs deductions.

Any other HMRC have previously published a Spotlight on

information HMRC agency workers and contractors employed by
considers relevant umbrella companies Spotlight 60. HMRC are
to publish about aware that some umbrella companies operate
these schemes more than one scheme, such as a standard
compliant scheme and a non-compliant
scheme. HMRC advise scheme users to
familiarise themselves with the guidance and to
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satisfy themselves that the correct amount of tax is

being deducted on their income.

Olympus Contracting Limited

We have published 2 entries that relate to this scheme operated
by Olympus Contracting Limited:

entry 1 – published under the Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Details of persons Olympus Contracting Limited (OCL) / Jordan

suspected of Dobney (former director of OCL) / Oliver Ames
promoting the scheme, – sole director of OCL
or of being a connected
person

Addresses of Olympus Contracting Limited, 63-66 Hatton

promoters suspected Garden, London, EC1N 8LE
of promoting the
scheme

Date of publication 25 September 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve users providing their

claimed to work services to end clients through OCL. The users
sign a contract of employment that will pay
them a basic salary at or around the rate of
National Minimum Wage or National Living
Wage salary which is subjected to Income Tax
and National Insurance contributions (NICs).
Scheme users also receive a secondary
payment. This secondary payment is paid by a
third-party or by OCL itself without Income Tax
or NICs being deducted.

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Any other information HMRC have previously published Spotlight 45

HMRC considers and Spotlight 60 guidance on disguised
relevant to publish remuneration schemes involving umbrella
about these schemes companies based on similar arrangements.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop Notice
has been published

Date arrangements 7 December 2023

subject to Stop Notice
published

Date name of promoter 21 March 2024

subject to Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a stop

notice

On the Box Pay Ltd

Details of persons On the Box Pay Ltd (OTBP)

suspected of
promoting the
scheme, or of being
a connected person

Addresses of Blinkbox Business Complex, Western Road, Deal,

persons suspected Kent, CT14 6PJ
of promoting the
scheme

Date of publication 8 August 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

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How the scheme is Scheme user enters into a contract of employment

claimed to work with OTBP providing their services to end clients
through OTBP. OTBP invoice the end client for the
work and, on receiving payment, make a single
payment to the user made up of 2 elements. The
first element is salary paid at the minimum rate
permitted under the National Minimum Wage Act
1998, and the second element is an amount
described as either a ‘Commission’, ‘Grantee’s
payment’, ‘Discretionary Share Bonus Payment’,
etc. There are deductions for Income Tax and
National Insurance contributions on the first
element of the payment, but not on the secondary
element.

Any other HMRC view is that the untaxed element is normal

information HMRC income, and Income Tax and NICs is therefore
considers relevant payable on the entire amount. HMRC have
to publish about previously published a Spotlight on agency
these schemes workers and contractors employed by umbrella
companies Spotlight 60.

Optima Limited
Details of persons Optima Limited (Optima) – Registered in the Isle of
suspected of Man (in liquidation) / Anthony Pithers (Director
promoting the of Optima) / Frank Umbrella Limited (FUL) (in
scheme, or of being liquidation) / Contractor Corner Accounting Limited
a connected person (CCA) (in liquidation)

Addresses of Optima Limited (in liquidation), Previous registered

promoters office: 6th Floor, Harbour Court, Lord Street,
suspected of Douglas, Isle of Man, IM1 LN) / Frank Umbrella
promoting the Limited (in liquidation), Previous registered office:
scheme 23 Chantry Lane, Grimsby, NE Lincolnshire, DN31
2LP) / Contractor Corner Accounting Limited (in
liquidation), Previous registered office: Suite 1,
Plymouth House, Plymouth Road, Blackpool, FY3
7JS (Registered office from 18 May 2021 to 26 April
2023)

Date of publication 5 September 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

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How the scheme is The scheme users sign a contract of employment

claimed to work and a commercial loan agreement with Optima,
based in the Isle of Man. Optima then contracts with
FUL and CCA (the ‘UK umbrella Companies’) for
the scheme user’s services. The UK umbrella
companies then contracts the scheme user’s
services to a UK intermediary/agency. The UK
intermediary/agency then contracts the scheme
user’s services to the end client. The end client
pays the UK intermediary/agency for the scheme
user’s services, who in turn pay the UK umbrella
companies. The UK umbrella companies pay the full
amount received to Optima, who then pays a fee to
the UK umbrella companies. Optima then pays a
National Minimum Wage/National Living Wage
salary to the scheme users with Income Tax and
National Insurance contributions (NICs) deducted,
and a payment, described as a loan and made
pursuant to the loan agreement, without deductions
of Income Tax and NICs.

Any other HMRC’s view is that the untaxed payments are

information HMRC actually no different to normal income, and tax and
considers relevant National Insurance contributions are payable.
to publish about HMRC have previously published information about
these schemes the tax avoidance arrangements used by some
umbrella companies Spotlight 60. HMRC are aware
that some umbrella companies operate more than
one scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of Optima to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

PAYE Services Limited

We have published 2 entries that relate to this scheme operated
by PAYE Services Ltd:

entry 1 – published under the Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

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Scheme entry 1

Details of persons PAYE Services Limited (PSL) / Simon Peter

suspected of Whitehead (Director of PSL)
promoting the
scheme, or of being a
connected person

Addresses of PAYE Services Limited, 7 Bell Yard, London,

promoters suspected WC2A 2JR
of promoting the
scheme

Date of publication 28 June 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is Arrangements involve users signing a ‘Contract

claimed to work – for Employment’ with PAYE Services Limited
summary (PSL) that will pay them at a rate of National
Living Wage (NLW) for each hour worked. They
also sign a ‘Master Advance Agreement’. The
user provides services to the end client and
submits timesheets to PSL for the work done.
PSL pays the user a single payment comprising
of the NLW salary (with any holiday pay) and the
Advance. The payment in relation to the Advance
is made without the deduction of Income tax or
National Insurance contributions.

Any other information PSL sells its services via the website [Link].
HMRC considers PSL claims that it commits to provide further
relevant to publish benefits to its employees, and that it is obliged to
about these schemes make employee incentivisation payments from its
gross profits in the form of contributions to an
‘Investment Employee Incentivisation Scheme’
(IEIA); where it intends to invest these
contributions in a Cayman hedge fund to
generate further profits for its
Beneficiaries. HMRC has seen no evidence to
suggest this exists or takes place.

Scheme entry 2

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Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop
Notice has been
published

Date arrangements 27 July 2023

subject to Stop
Notice published

Date name of 10 November 2023

promoter subject to
Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a stop

notice

PAYEme Ltd

Name of promoter PAYEme Ltd

Date arrangements subject to Stop 2 March 2023

Notice published

Date name of promoter subject to 18 April 2024

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

Payeworx Ltd

Details of persons Payeworx Ltd (PWL) / Contractor Buddy PCC

suspected of Limited (CBP) (Incorporated in Isle of Man)
promoting the
scheme

Addresses of Payeworx Ltd, Newspaper House, Tannery Lane,

promoters Penketh, Warrington, Cheshire, WA5 2UD /
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suspected of Contractor Buddy PCC Limited, 2nd Floor,

promoting the Murdoch Chambers, South Quay, Douglas, Isle of
scheme Man, IM1 5AS

Date of publication 24 August 2023

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme user enters into an employment

claimed to work contract with PWL, and the scheme user’s
Personal Service Company (PSC) is issued a
share in CBP, a connected protected cell company
based in the Isle of Man (IOM). PWL pay the
scheme user a salary that is around the minimum
amount required by the National Minimum Wage
Act 1998. CBP make a separate larger payment
without deducting Income Tax and National
Insurance contributions to the scheme user’s PSC,
supposedly for a dividend. CBP deduct around 2%
from the larger payment as a fee, and a further
19% which they claim is Corporation Tax (CT).
However, the rate of CT in the IOM is 0%. The
scheme users are expected to distribute the
alleged dividend amount as they see fit.

Any other HMRC have previously published Spotlight 60

information HMRC guidance on disguised remuneration schemes.
considers relevant
to publish about
these schemes

Pay Rec Limited

Details of persons Pay Rec Limited (PRL)

suspected of having
any other role in
relation to making the
scheme available for
implementation.

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Addresses of persons 1 Piccadilly Business Centre, Aldow Enterprise

suspected of having Park, Manchester, United Kingdom, M12 6AE
any other role in
relation to making the
scheme available for
implementation

Date of publication 31 August 2023

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is Scheme users enter into an employment

claimed to work contract with PRL, which also invites them into
a bonus scheme. PRL pays the scheme users a
salary around the National Minimum Wage or
National Living Wage with Income Tax and
National Insurance contributions (NICs)
deducted. At, or around the same time, the
scheme users also receive a second payment,
described as an advance against future bonus
payments. This is paid without Income Tax
and NICs deducted.

Any other information It is HMRC’s view that the ‘advances’, paid

HMRC considers against future bonus payments, are no different
relevant to publish to normal income, and are therefore taxable.
about these schemes HMRC have previously published Spotlight 60
guidance for agency workers and contractors
employed by umbrella companies. HMRC
advise employees of PRL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is
being deducted on their income.

Payroll Professors Limited

Details of persons Payroll Professors Limited (Company Registration

suspected of Number: 15492817)
promoting the
scheme

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Addresses of 7 Bell Yard, London, WC2A 2JR

persons suspected
of promoting the
scheme

Date of publication 13 March 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Payroll Professors Limited. Some
employees of Payroll Professors Limited receive
part of their renumeration as a salary, paid at or
close to the minimum rate permitted under the
National Minimum Wage Act 1998 (NMW), that is
subject to deductions for Income Tax and National
Insurance contributions (NICs). The employees
also receive a second element of their
remuneration which is made without deduction of
Income Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC suspects that the
arrangement is targeted at local authority workers.
HMRC is aware that some umbrella companies
operate more than one scheme, such as a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of Payroll
Professors Limited to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

Paystone Services Limited

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Details of persons Paystone Services Limited (PSL) (also known as

suspected of Artifact Services)
promoting the
scheme

Addresses of 48 West George Street, Clyde Offices, 2nd Floor,

persons suspected Glasgow, Scotland, G2 1BP
of promoting the
scheme

Date of publication 1 February 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is PSL pay scheme users a salary, which is

claimed to work approximately at the National Minimum Wage or
National Living Wage rate, with tax and National
Insurance contributions (NICs) deducted. However,
they also receive a secondary payment without
deduction of tax and NICs. This may be labelled as
‘Share payment’, ‘Option payment’ or something
else. The secondary payment is the remaining
balance of their contractual payment for the work
carried out, minus a fee that PSL deduct for the
operation of the scheme.

Any other The scheme is targeted predominantly at workers

information HMRC within health, tech and energy sectors. Those in
considers relevant health, include doctors, nurses, speech therapists
to publish about and podiatrists. HMRC do not accept these
these schemes arrangements work as claimed. Tax
and NICs should be accounted for on both
payments under PAYE as they are made in respect
of work carried out by the scheme user. It
is HMRC’s view that the 2 payment arrangements
are set up purely to facilitate a disguised
remuneration tax avoidance scheme. HMRC is
aware that some umbrella companies operate more
than one scheme, for example a standard compliant
scheme and a non-compliant
schemes. HMRC advise employees of PSL to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

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Pazepay Limited

Details of persons Pazepay Limited (PPL)

suspected of
promoting the
scheme

Addresses of 20 Colmore Circus, Queensway, Birmingham, B4

persons suspected 6AT
of promoting the
scheme

Date of publication 29 August 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of PPL. Employees receive part of their
PPL remuneration at a rate close to the National
Minimum Wage or National Living Wage which is
subjected to Income Tax and National Insurance
contributions (NICs). Employees receive the
balance of their remuneration without the deduction
of Income Tax or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore should
to publish about be subjected to Income Tax and NICs. HMRC have
these schemes previously published Spotlight 60 on disguised
remuneration schemes involving agency workers
and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC also has reason to
suspect that PPL target healthcare sector, NHS and
Council employees. HMRC advise employees of
PPL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount of
tax is being deducted on their income.

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Peak PAYE Limited

Name of promoter Peak PAYE Limited

Legislation under which this Stop Promoters of Tax Avoidance

Notice has been published Schemes (POTAS)

Date arrangements subject to Stop 13 April 2023

Notice published

Date name of promoter subject to 7 June 2023

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

Penhale Solutions Limited

Details of persons Penhale Solutions Limited (PSL)

suspected of
promoting the
scheme

Addresses of Former address: 71-75 Shelton Street, London,

promoters WC2H 9JQ / Current Address (as of 25 September
suspected of 2024): 128 City Road, London, EC1V 2NX
promoting the
scheme

Date of publication 16 January 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work – employees of PSL. PSL employees receive part of
summary their remuneration at a rate close to the National
Minimum Wage or National Living Wage which is
subject to Income Tax and National Insurance
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contributions (NICs). Employees receive the

balance of their remuneration without the deduction
of Income Tax or NICs.

Any other HMRC’s view is that both elements of

information HMRC the PSL employees pay should be treated as
considers relevant ‘normal income/as the user’s salary’, and therefore
to publish about subject to Income Tax and NICs. HMRC have
these schemes previously published Spotlight 60 on disguised
remuneration schemes involving agency workers
and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advise employees
of PSL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

Pinnacle and Partners Limited

Details of persons Pinnacle and Partners Limited / Omni Contractors

suspected of PCC Limited (OCP) / Enya Elizabeth Torres
promoting the (Director of Pinnacle and Partners Limited) / Mr
scheme, or of being Paul Middleton (Director of OCP)
a connected person

Addresses of Pinnacle and Partners Limited: 27 Old Gloucester

persons suspected Street, London, WC1N 3AX / OCP: Unit 2 Close
of promoting the Beg, Peel, Isle of Man IM5 1XF
scheme

Date of publication 23 January 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Some employees of Pinnacle and Partners Limited

claimed to work receive part of their remuneration as a salary that
is subjected to Income Tax and National Insurance
contributions (NICs). They also receive a
secondary element of their remuneration that is not
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subjected to the deduction of Income Tax and

NICs. The secondary element is claimed to relate
to the growth in the value of a share held by the
employee in OCP.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC have previously
published information on umbrella companies
offering to increase your take home pay Spotlight
45. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
Pinnacle and Partners Limited to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Prime Umbrella Services Ltd

We have published 2 entries that relate to this scheme operated by Prime
Umbrella Services Ltd:

entry 1 – published under the Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Details of persons Prime Umbrella Services Ltd / Adam

suspected of promoting Whitehead (Director of Prime Umbrella
the scheme, or of being a Services Ltd) / Wilson Costello Limited /
connected person, or Jonathan Milne (Director of Wilson Costello
having any other role in Limited)
relation to making the
scheme available for
implementation

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Addresses of persons Prime Umbrella Services Ltd, 128 City Road,

suspected of promoting London, United Kingdom, EC1V 2NX
the scheme

Date of publication 31 August 2023

Legislation under which Finance Act 2022

this scheme/promoter
has been named

How the scheme is Arrangements involve a user providing their

claimed to work services to end clients/recruitment agencies
through Prime Umbrella Services Ltd and
receiving 2 payments, one equivalent to
National Minimum Wage (NMW) or, if
applicable, the National Living Wage (NLW)
salary and a second payment, described as a
‘pass through item’, on behalf of Wilson
Costello Limited. The result is that the total
remuneration for the users’ services is
artificially separated into 2 payments. The first
is a salary (equivalent to NMW/NLW) with tax
and National Insurance contributions (NICs)
deducted, and a second payment which is
made without tax or NICs deducted.

Any other information HMRC have allocated Scheme Reference

HMRC considers relevant Number 79390150 to these arrangements.
to publish about these You can find out what this means for you by
schemes reading the DOTAS guidance at Disclosure of
tax avoidance schemes. HMRC have also
previously published Spotlight 60 guidance
on disguised remuneration schemes warning
agency workers and contractors employed by
umbrella companies.

Scheme entry 2

Legislation under which Promoters of Tax Avoidance Schemes

this Stop Notice has been (POTAS)
published

Date arrangements 18 April 2024

subject to Stop Notice
published

Date name of promoter 18 April 2024

subject to Stop Notice
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published

POTAS publication List of tax avoidance schemes subject to a

stop notice

PRC Recruitment Ltd

Details of persons PRC Recruitment Ltd (PRC) (Company

suspected of Registration Number: 14106838)
promoting the
scheme

Date of publication 13 March 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of PRC. Employees receive part of
their PRC remuneration at a rate close to the
National Minimum Wage or National Living Wage
which is subjected to deductions for Income Tax
and National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deductions of Income Tax
or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ pay are employment income, and
considers relevant therefore subject to Income Tax and NICs. HMRC
to publish about have previously published Spotlight 60 on
these schemes disguised remuneration schemes involving agency
workers and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC also has reason to
suspect that PRC target social workers and
employees in the health care sector. HMRC advise
employees of PRC to familiarise themselves with
the guidance and to satisfy themselves that the

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correct amount of tax is being deducted on their

income.

Procorre LLP

Details of persons Procorre LLP (Registered in Singapore) / Corre

suspected of Holdings SA (Registered in Switzerland) / Mr
promoting the Darren Patrick-Green (also known as Mr Darren
scheme, or of being Green) / Mr Jason Bougourd / Ms Alizeh Nanji
a connected person

Addresses of Procorre LLP: 33 Ubi Avenue 3, #08-61,

persons suspected Singapore 408868, Republic of Singapore / Corre
of promoting the Holdings SA: Rue du Rhône 118 Genève,
scheme, or of being GENÈVE, 1204 Switzerland
a connected person

Date of publication 29 February 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Scheme users and their personal service

claimed to work companies (PSCs) join and become members in
Procorre LLP (Procorre). The PSC’s then enter
into contracts to provide the services of the
scheme users to end clients. The PSC’s invoices
the end clients [on behalf of Proccore] and transfer
the income received to Procorre. Procorre return
the income to the PSC’s and the users after
deducting a fee. The income is returned via direct
payment to the PSC’s bank accounts, and in the
form of untaxed drawings, pre-paid expense cards
and business development fund payments all
provided by Procorre.

Any other It is HMRC’s view that the drawings, pre-paid

information HMRC expense cards and business development fund
considers relevant to payments received by users represent the rewards
publish about these for their services provided to end clients and
schemes should therefore be subject to Income Tax and
National Insurance contributions. HMRC have
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previously issued a Spotlight on Disguised

Renumeration Asset Transfer Arrangements
intended to avoid the loan charge. The individuals
named are connected persons due to their control
over the LLP. Mr Patrick-Green is the Ultimate
Beneficial Owner of Corre Holdings SA (CHSA).
CHSA is a designated member and majority owner
of the LLP. HMRC also suspect that CHSA are
involved in moving Users to a further set of
arrangements which involve the acquisition of their
PSC.

Property118 Ltd
We have published entries that relate to 2 schemes operated by Property
118 Ltd:

scheme 1 – published under Disclosure of Tax Avoidance Schemes

(DOTAS)
scheme 2 – published under Disclosure of Tax Avoidance Schemes
(DOTAS)

Scheme entry 1

Name of scheme Substantial Incorporation Structure

Name of promoter Property118 Ltd (P118) / Cotswold Barristers Ltd

or supplier of (CBL)
scheme

Address of P118: 1st Floor Woburn House, 84 St. Benedicts

promoter or Street, Norwich, Norfolk, NR2 4AB / CBL: D5
supplier of scheme Cotswold Airport, Kemble, Gloucestershire, England,
GL7 6BA

Date of publication 19 September 2024

Scheme Reference 53560969

Number (SRN)

Date SRN allocated 9 February 2024

to the scheme

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Legislation under Disclosure of Tax Avoidance Schemes (DOTAS)

which this
scheme/promoter
has been named

Statutory Section 162 Taxation of Capital Gains Act 1992

Provisions on
which the tax
advantage is
based

How the scheme is Users enter into a ‘Sale and Purchase Agreement’ to
claimed to work sell their property business to a company wholly in
exchange for shares. They also enter a Trust Deed,
Agency Agreement and Contract for Sale. The trust
holds the legal interest in the properties and the
Contract for Sale allows for a delay on the transfer of
legal titles. The mortgage liabilities are not actually
transferred or repaid. Instead, the company adopts
responsibility for the liabilities in the form of an
indemnity. Users are appointed as agents of the
company to make and receive payments, including
mortgage payments for the properties. Once the
transfer has taken place, the company holds the
beneficial interests in the properties. It also, as per
the indemnity, reimburses the user for the mortgage
payments the user makes, and claims interest relief
against its profits. It is claimed that there is no capital
gains tax on the sale due to rollover relief for transfer
of business assets.

Scheme entry 2

Name of scheme Capital Account Restructure

Name of promoter Property118 Ltd (P118) / Cotswold Barristers Ltd

or supplier of (CBL) / Succeed in Property Ltd (SIPL)
scheme

Address of P118: 1st Floor Woburn House, 84 St. Benedicts

promoter or Street, Norwich, Norfolk, NR2 4AB / CBL: D5
supplier of Cotswold Airport, Kemble, Gloucestershire, England,
scheme GL7 6BA / SIPL: 2nd Floor (Rear Suite), 54-56
Victoria Street, St Albans, AL1 3HZ

Date of publication 19 September 2024

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Scheme Reference 07626525

Number (SRN)

Date SRN allocated 9 February 2024

to the scheme

Legislation under Disclosure of Tax Avoidance Schemes (DOTAS)

which this
scheme/promoter
has been named

Statutory Section 162 Taxation of Capital Gains Act 1992

Provisions on
which the tax
advantage is
based

How the scheme is Scheme users, a company they manage, and a

claimed to work lender enter a ‘facility agreement’ for a bridging loan.
Users then enter an agreement to sell their property
business to their company in exchange for shares. A
trust holds the legal interest in the properties and a
Contract for Sale is used to delay the transfer of
legal title. The business’ liabilities are not actually
repaid; the company adopts responsibility for them in
the form of an indemnity. Users are appointed
agents of their company to handle its payments.
Users draw down the bridging loan prior to the sale
completion; however, the company will become
responsible for the loan post transfer and will not
have funds to repay the loan. After the transfer, the
users loan the company the required amount to
repay the bridging loan. The users’ director’s loan
account is credited with the loaned amount, which
they expect to draw from tax free. It is claimed that
no capital gains tax is due on the sale due to rollover
relief for transfer of business assets.

Protean Ltd

Details of persons Protean Ltd (PL) / Mr Jonathan Milne (Director of

suspected of Protean Ltd)
promoting the

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scheme, or of being
a connected person

Addresses of 128 City Road, London, EC1V 2NX

persons suspected
of promoting the
scheme

Date of publication 21 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Scheme users provide services to end clients as

claimed to work employees of PL. PL pay scheme users part of their
remuneration as a salary close to, or in line with,
the rate of National Minimum Wage or National
Living Wage and this is subjected to Income Tax
and National Insurance contributions (NICs). The
scheme users also receive a secondary element of
remuneration that is not subjected to the deduction
of Income Tax and NICs.

Any other HMRC’s view is that both elements of the

information HMRC employee’s pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore should
to publish about be subjected to Income Tax and NICs. Jonathan
these schemes Milne was identified as a director of Wilson Costello
Ltd which was published under Finance Act 2022
on 31 August 2023. HMRC have previously
published Spotlight 60 on disguised remuneration
schemes involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate more
than one scheme, such as a standard compliant
scheme and a non-compliant scheme. HMRC has
reason to suspect that PL target social workers in
North West England, working in the care sector and
for local council authorities. HMRC advise
employees of PL to familiarise themselves with the
guidance and to satisfy themselves that the correct
amount of tax is being deducted on their income.

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Purity Ltd

Details of persons Purity Ltd / Rebecca Waterfield (Director of Purity

suspected of Ltd)
promoting the
scheme, or of being
a connected person

Address of person 85 Great Portland Street, London, W1W 7LT

suspected of
promoting the
scheme

Date of publication 25 January 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Purity Ltd (‘Purity’) employees provide their

claimed to work services to an end client via a recruitment agency.
The recruitment agency pays Purity for the work
done by the employees. Purity then makes 2
payments to the employees. The first payment, a
salary at the National Minimum Wage or National
Living Wage rate, described on bank statements
as ‘Purity Salary’ is made with Income Tax and
National Insurance contributions (NICs) deducted.
The second payment, described on bank
statements as ‘Purity Adv’ is made without Income
Tax and NICs deducted.

Any other HMRC’s position is that the untaxed payment

information HMRC described on bank statements as ‘Purity Adv’ is
considers relevant normal income, and Income Tax and NICs are
to publish about payable on it. HMRC have previously published
these schemes Spotlight 60 information about the tax avoidance
arrangements used by some umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, for
example, a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
Purity to familiarise themselves with the guidance

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and to satisfy themselves that the correct amount

of tax is being deducted on their income.

Purple Pay Limited

Name of promoter Purple Pay Limited

Date arrangements subject to Stop 13 April 2023

Notice published

Date name of promoter subject to 7 December 2023

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

Rainbowpay Ltd
We have published 2 entries that relate to a scheme operated by
Rainbowpay Ltd:

entry 1 – published under Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Details of persons Rainbowpay Ltd / Lyndsey Pauline Scott –

suspected of (Former Director of Rainbowpay Ltd) / Sunil
promoting the scheme, Lekhi – (Former Director of Rainbowpay Ltd) /
or of being a connected Flexen Ltd (Incorporated in Cyprus) / Giannakis
person, or having any Fysentzou (Director of Flexen Ltd and counter
other role in relation to signatory to the Annuity Agreements)
making the scheme
available for
implementation

Addresses of persons Rainbowpay Ltd, formerly of 40 Caversham

suspected of Road, Reading, RG1 7EB, now of Blinkbox
promoting the scheme, Business Complex, Western Road Deal Kent,
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or having any other CT14 6PJ / Flexen Ltd, Stratigou Timagia,

role in relation to formerly of 15 Linda Court, 3rd Floor 6051,
making the scheme Larnaca, Cyprus, now of Zakynthu 2, Flat /
available for Office 1, 6018, Larnaca, Cyprus
implementation

Date of publication 1 December 2023

Publication last 13 February 2025

updated

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve individuals providing

claimed to work their services to end clients or agencies through
Rainbowpay Ltd who operate the payroll. The
individuals also enter into an agreement with
Flexen Ltd where individuals grant Flexen Ltd
the option to enter an Annuity Agreement in
exchange for payments (the ‘Grantee
Payments’). The individuals receive payslip
from Rainbowpay Ltd showing Income and
Deductions including Tax and National
Insurance contributions (NICs). This amount is
subsequently reported to HMRC. However, the
amount actually paid into the individual’s bank
account is greater than the amount shown on
the payslip and the difference between these
two amounts has not been subjected to Tax or
NIC. It is HMRC’s view that the amount paid
without tax and NIC deductions represents the
‘Grantee Payments’ but paid by Rainbow Ltd on
behalf of Flexen Ltd. It is also HMRC’s view that
the ‘Grantee Payments’ are also income for the
services provided by individuals through
Rainbowpay Ltd, and therefore the entire
payment should be subject to tax and NIC
deductions.

Any other information HMRC have now notified both Rainbowpay Ltd
HMRC considers and Flexen Ltd that a Scheme Reference
relevant to publish Number, 58772053, has been allocated to the
about these schemes arrangements. You can find out what this
means for you by reading the Disclosure of Tax
Avoidance Schemes (DOTAS) guidance. HMRC

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have previously published Spotlight 60 on

agency workers and contractors employed by
umbrella companies.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop Notice
has been published

Date arrangements 12 September 2024

subject to Stop Notice
published

Date name of promoter 6 March 2025

subject to Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a stop

notice

Rainwize Umbrella Limited

Details of persons Rainwize Umbrella Limited (RUL)

suspected of
promoting the
scheme

Addresses of 307 Cotton Exchange Building, Old Hall Street,

persons suspected Liverpool, L3 9LQ
of promoting the
scheme

Date of publication 16 January 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of RUL. Employees receive part of their
RUL remuneration at a rate close to the National
Minimum Wage or National Living Wage which is
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subjected to deductions for Income Tax and

National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deduction of Income Tax
or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and
contractors employed by umbrella companies.
HMRC also has reason to suspect that RUL target
social workers. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of RUL to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

React Administration Services Limited

Details of persons React Administration Services Limited (RASL) /

suspected of Kevin Taylor (Director of RASL)
promoting the
scheme, or of being
a connected person

Addresses of 2 Brunel Way, Slough, SL1 1XL

persons suspected
of promoting the
scheme

Date of publication 29 February 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

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How the scheme is The scheme user enters an employment contract

claimed to work with React Administration Services Limited (RASL)
and provides their services to an end client. RASL
then makes a single payment to the scheme user
for their services, but this is artificially separated
into 2 elements. The first element is a salary paid
at or around National Minimum Wage or National
Living Wage with tax and National Insurance
contributions (NICs) deducted. The secondary
element is described as a ‘propelled payment’ with
no tax and NICs deducted.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant to salary’, and therefore subject to tax and
publish about these NICs. HMRC have previously published Spotlight
schemes 60 guidance on disguised remuneration schemes
involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate
more than one scheme, for example a standard
compliant scheme and a non-compliant
scheme. HMRC advise employees of RASL to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

Remuneration Assured Ltd

Details of persons Remuneration Assured Ltd (RAL)

suspected of
promoting the
scheme

Date of publication 13 February 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of RAL. Employees receive part of
their RAL remuneration at a rate close to the
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National Minimum Wage or National Living Wage

which is subjected to deductions for Income Tax
and National Insurance contributions (NICs).
Employees receive the balance of their RAL
remuneration without the deduction of Income Tax
or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ pay are employment income, and
considers relevant to therefore subject to Income Tax and NICs. HMRC
publish about these have previously published Spotlight 60 on
schemes disguised remuneration schemes involving agency
workers and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
RAL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

Resource Hubco Limited

Details of persons Resource Hubco Limited (RHL) / Cornelia Van-

suspected of Der-Sluis (Director of RHL)
promoting the
scheme, or of being
a connected person

Addresses of 3 Piccadilly Place, Manchester, M1 3BN

promoters
suspected of
promoting the
scheme

Date of publication 28 June 2023

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme user enters an employment contract

claimed to work with RHL who make composite payments to the
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scheme users for services provided by the user.

The first element is a National Minimum
Wage/living wage salary that is subjected to tax
and National Insurance contributions, and a
secondary element described as an ‘advance
drawn down’ which is not.

Any other HMRC’s view is that these payments are actually

information HMRC no different to normal income, and tax and
considers relevant National Insurance contributions are
to publish about payable. HMRC have previously published
these schemes Spotlight 60 information about the tax avoidance
arrangements used by some umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, eg a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of RHL to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

Rosewood WM IO Services Ltd

Details of persons Rosewood WM IO Services Ltd (in

suspected of promoting liquidation) (RWM)/ Elliott Lee Bushby –
the scheme, or of being a former director of Rosewood WM IO Services
connected person, or Ltd / James Grubb – director of Rosewood
having any other role in WM IO Services Ltd / Dynasty Payroll
relation to making the Solutions Ltd
scheme available for
implementation

Addresses of persons Rosewood WM IO Services Ltd (in

suspected of promoting liquidation), 3rd Floor 86-90 Paul Street,
the scheme, or of being a London, EC2A 4NE / Dynasty Payroll
connected person, or Solutions Ltd, International House, Admirals
having any other role in Way, London, E14 9XL
relation to making the
scheme available for
implementation

Date of publication 8 August 2024

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Legislation under which Finance Act 2022

this scheme/promoter has
been named

How the scheme is The arrangements involve users providing

claimed to work their services to end clients through RWM.
The users sign a contract of employment with
RWM that will pay them a basic salary at or
around the rate of National Minimum Wage
or National Living Wage salary which is
subject to Income Tax and National
Insurance contributions (NICs) deductions.
The users also receive an additional payment
(described as a withdrawal) from RWM
without Income Tax and NICs deductions.
The payments from the end clients to RWM
are sometimes routed via Dynasty Payroll
Solutions Ltd.

Any other information HMRC’s view is that both elements of the

HMRC considers relevant payment should be treated as ‘normal
to publish about these income/as the user’s salary’ and therefore,
schemes subject to Income Tax and NICs. HMRC have
previously published Spotlights on disguised
remuneration schemes involving umbrella
companies Spotlight 45 and Spotlight 60
based on similar arrangements. HMRC
advise employees of RWM to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is
being deducted on their income.

RW Operations Ltd

Details of persons RW Operations Ltd (RWO)

suspected of
promoting the
scheme

Addresses of 85 Great Portland Street, London, W1W 7LT

persons suspected
of promoting the
scheme

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Date of publication 8 August 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide their services to end clients as

claimed to work employees of RWO. Employees
of RWO participating in the arrangements receive
part of their remuneration as a salary paid at a rate
close to the minimum permitted under the National
Minimum Wage (NMW) Act 1998. That amount is
subjected to deductions for income tax and
National Insurance contributions (NICs). The
remaining balance of the remuneration is paid to
the employees without deductions for Income Tax
and NICs.

Any other HMRC’s view is that both elements of pay should

information HMRC be treated as normal income/as the user’s salary,
considers relevant and therefore subject to Income Tax
to publish about and NICs. HMRC have previously published
these schemes Spotlight 60 on disguised remuneration schemes
involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant scheme.
HMRC advise employees of RWO to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Saxonside Limited
We have published 2 entries that relate to schemes operated by Saxonside
Limited:

entry 1: Saxonside Option Grant – published under Promoters of Tax

Avoidance regime
entry 2: Saxonside Share Growth – published under Finance Act 2022

Saxonside Limited – Saxonside Option Grant

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Name of promoter Saxonside Limited (SAX)

Legislation under which this Stop Promoters of Tax Avoidance

Notice has been published Schemes (POTAS)

Date arrangements subject to Stop 2 March 2023

Notice published

Date name of promoter subject to 7 June 2023

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

Saxonside Limited – Saxonside Share Growth

Name of scheme Saxonside Share Growth

Details of persons Saxonside Limited (SAX), Omni Contractors PCC

suspected of Limited (OCP), Adam Fathers (director of SAX),
promoting the Kirsty LeMarechal (former director of OCP)
scheme, or of being
a connected person

Addresses of Saxonside Limited: Centaur House, Ancells Road,

promoters Fleet GU51 2UJ / Omni Contractors PCC Limited:
suspected of Unit 2 Close Beg, Peel, Isle of Man IM5 1XF
promoting the
scheme

Date of publication 31 August 2022

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme users enter into an employment

claimed to work – contract with SAX and receive a share in OCP, a
summary separate, protected cell company. The share is
unique to the scheme user’s name. SAX pay the
scheme user a National Minimum Wage (NMW)
salary through the payroll and OCP makes an
additional payment that is allegedly for the growth
in the share’s value. This is paid without Income
Tax and National Insurance contributions (NICs)
deductions. SAX alleges that the payment will later
be subject to capital gains tax (CGT), and they
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retain an amount that they will allegedly release

back to scheme users to cover any future CGT
liability. Scheme users retain around 71 to 73% of
the expected gross contract value. Read more
detail about how this scheme operates.

Signature Pay Limited

Details of persons Signature Pay Limited (SPL) / Mr Samuel Joseph

suspected of Heys (Director of SPL)
promoting the
scheme, or of being
a connected person

Addresses of Peter House, Oxford Street, Manchester, M1 5AN

persons suspected
of promoting the
scheme

Date of publication 10 October 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of SPL. SPL pay scheme users part of
their remuneration as a salary close to, or in line
with, the rate of National Minimum Wage or
National Living Wage as set out in SPL contract of
employment, and which is subjected to Income Tax
and National Insurance contributions (NICs). The
scheme users also receive a secondary element of
their remuneration that is not subjected to the
deduction of Income Tax and NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore should
to publish about be subjected to Income Tax and NICs. HMRC have
these schemes previously published Spotlight 60 on disguised
remuneration schemes involving agency workers
and contractors employed by umbrella companies.
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HMRC are aware that some umbrella companies

operate more than one scheme, such as a
standard compliant scheme and a non-compliant
scheme. HMRC also has reason to suspect that
SPL target healthcare sector, NHS and Council
employees. HMRC advise employees of SPL to
familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

Signature Vintage Limited

Details of persons Signature Vintage Limited (SVL)

suspected of
promoting the
scheme, or of being
a connected person

Address of persons 71-75 Shelton Street, London, Greater London,

suspected of WC2H 9JQ
promoting the
scheme

Date of publication 16 May 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Signature Vintage Limited (SVL) employees

claimed to work provide their services to an end client via a
recruitment agency. The recruitment agency pays
SVL for the work carried out by the employees.
SVL makes a single payment to the employees
each week. Part of the payment is salary at a rate
close to the National Minimum Wage with Income
Tax and National Insurance contributions (NICs)
deducted, and the remaining balance is allegedly
for an ‘Option Granted’ which is paid to the
employees without deductions for Income Tax and
NICs.

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Any other HMRC’s position is that the payment described as

information HMRC an ‘Option Granted’ is normal income and should
considers relevant therefore be subject to Income Tax and
to publish about NICs. HMRC have previously published
these schemes information about the tax avoidance arrangements
used by some umbrella companies Spotlight
60. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advise employees of
SVL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

SmartPay Limited

Name of scheme SmartPay Third Party Loan

Name of promoter SmartPay Limited (Incorporated in the Isle of Man)

or supplier of (SmartPay (IOM)) / SmartPay Limited (Incorporated
scheme in the UK) (SmartPay (UK))

Address of SmartPay Limited, 3A Samuel Harris House, 5-11 St

promoter or Georges Street, Douglas, Isle of Man, IM1 1AJ /
supplier of scheme SmartPay Limited, Blackpool Technology
Management Centre, Faraday Way, Blackpool,
Lancashire, FY2 0JW

Date of publication 24 August 2023

Scheme Reference 62482307

Number (SRN)

Date SRN allocated 23 June 2022

to the scheme

Legislation under Disclosure of Tax Avoidance Schemes (DOTAS)

which this
scheme/promoter
has been named

Statutory Section 62 Income Tax (Earnings and Pensions) Act

Provisions on 2003 (ITEPA)

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which the tax

advantage is based

How the scheme is SmartPay (IOM) signs an employment agreement

claimed to work – with the scheme user and a contract for services
summary with SmartPay (UK). The user also enters into a
‘facility agreement’ with Smartpay (IOM), acting as
trustee for a related trust whereby the user is
provided with a loan facility. SmartPay (UK) then
enters a contract for services with a recruitment
agency for the user’s services. The recruitment
agency then enters a contract for services with the
end client. The end client pays the recruitment
agency for the scheme user’s services, who in turn
pay SmartPay (UK). Following the deduction of a
fee, SmartPay (UK) pay the remaining amount to
SmartPay (IOM). SmartPay (IOM) pays a salary in
line with the National Minimum Wage Act to the
scheme user and a payment described as a loan
which is made without deductions of Income Tax or
National Insurance contributions.

Judicial rulings HMRC v SmartPay Ltd [2022] UKFTT 146

relating to the
scheme

Solucionis Limited
We have published 2 entries that relate to this scheme operated
by Solucionis Limited:

entry 1 – published under the Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Details of persons Solucionis Limited (Solucionis)

suspected of
promoting the scheme

Addresses of persons Horton House, Exchange Flags, Liverpool,

suspected of England, L2 3PF
promoting the scheme

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Date of publication 25 April 2024

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The remuneration for the scheme users’ services
claimed to work is artificially separated into 2 elements. The first
is a salary with tax and National Insurance
(NICs) deducted. The second is purported to be
either for the growth in a share in an Isle of Man
cell company, or for an option grant, with no tax
and NICs deducted

Any other information HMRC’s view is that these payments are actually
HMRC considers no different to normal income, and tax and
relevant to publish National Insurance contributions are payable.
about these schemes HMRC have previously published information on
umbrella companies offering to increase your
take home pay (Spotlight 45). HMRC are aware
that some umbrella companies operate more
than one scheme, such as a standard compliant
scheme and one or more non-compliant
schemes. HMRC advise employees of Solucionis
to familiarise themselves with the guidance and
to satisfy themselves that the correct amount of
tax is being deducted on their income.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop Notice
has been published

Date arrangements 12 September 2024

subject to Stop Notice
published

Date name of 12 September 2024

promoter subject to
Stop Notice published

POTAS publication List of tax avoidance schemes subject to a stop

notice

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Stark Payment Services Ltd

Details of persons Stark Payment Services Ltd (SPSL) (In

suspected of Liquidation) / Martin Andrew Jones (Director
promoting the of SPSL)
scheme, or of being
a connected person

Addresses of Former address: Unity Building, 20 Chapel Street,

persons suspected Liverpool, L3 9AG
of promoting the
scheme

Date of publication 16 January 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Some employees of SPSL receive part of their

claimed to work remuneration as a salary that is subjected to
Income Tax and National Insurance contributions
(NICs). They also receive a secondary element of
their remuneration that is not subjected to the
deduction of Income Tax and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 in disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of SPSL to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax was deducted on their
income.

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Summit LED Ltd

Details of persons Summit LED Ltd (SLL) trading as Adept Pay / Sayf
suspected of Aashik (former director of SLL)
promoting the
scheme, or of being
a connected person

Addresses of Level One, Basecamp Liverpool, 49 Jamaica

persons suspected Street, Liverpool, Merseyside, England, L1 OAH
of promoting the
scheme

Date of publication 29 August 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is SLL trading as Adept Pay. SLL’s employees

claimed to work provide their services to an end client via a
recruitment agency. The recruitment agency
pays SLL for the work done by the
employees. SLL then make a single payment to
the employees each week. The payment is
artificially separated into 2 elements. The first
element is a salary, paid at a rate close to the
minimum permitted under the National Minimum
Wage (NMW) Act 1998, with Income Tax and
National Insurance contributions (NICs) deducted.
The second element, which has no description, is
made without the deduction of Income Tax
and NICs.

Any other HMRC’s position is that the whole payment is

information HMRC normal income, and Income Tax and NICs are
considers relevant payable on it. HMRC have previously published
to publish about information about the tax avoidance arrangements
these schemes used by some umbrella companies Spotlight 60.
HMRC are aware that some umbrella companies
operate more than one scheme, such as a
standard compliant scheme and a non-compliant
scheme. HMRC advise employees of SLL to
familiarise themselves with the guidance and to
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satisfy themselves that the correct amount of tax is

being deducted on their income.

Titan Payment Solutions Limited

Details of persons Titan Payment Solutions Limited (TPS)

suspected of
promoting the
scheme

Addresses of 196 High Road, Wood Green, London, N22 8HH

persons suspected
of promoting the
scheme

Date of publication 28 November 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of TPS. Employees of TPS receive part
of their remuneration as a salary, paid at or close to
the minimum rate permitted under the National
Minimum Wage Act 1998, and that is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). TPS employees also receive
a secondary element of their remuneration that is
not subjected to deduction of Income Tax and
NICs.

Any other It is HMRC’s view that both elements of the pay

information HMRC made to employees of TPS should be subject to
considers relevant Income Tax and NICs. HMRC has previously
to publish about published Spotlight 60 on disguised remuneration
these schemes schemes involving agency workers and contractors
employed by umbrella companies. HMRC is aware
that some umbrella companies operate more than
one scheme, such as a standard compliant
scheme and a non-compliant scheme. It appears
that TPS target NHS and Local Authority workers.
HMRC advises employees of TPS to familiarise
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themselves with the guidance and to satisfy

themselves that the correct amount of tax is being
deducted on their income.

Trident Umbrella Limited

Details of persons Trident Umbrella Limited / Michael Paul Griffin

suspected of (Director of Trident Umbrella Limited)
promoting the
scheme, or of being
a connected person

Addresses of Two Four Nine North, Lynnfield House, Church

persons suspected Street, Altrincham, England, WA14 4DZ
of promoting the
scheme

Date of publication 13 February 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Trident Umbrella Limited.
Employees receive part of their remuneration at a
rate close to the National Minimum Wage or
National Living Wage which is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). Employees receive the
balance of their remuneration without the
deduction of Income Tax or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ pay should be treated as ‘normal
considers relevant to income/as the user’s salary’, and therefore subject
publish about these to Income Tax and NICs. HMRC have previously
schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and
contractors employed by umbrella companies.
HMRC also has reason to suspect that Trident
Umbrella Limited target social workers. HMRC are
aware that some umbrella companies operate
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more than one scheme, such as a standard

compliant scheme and a non-compliant scheme.
HMRC advise employees of Trident Umbrella
Limited to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted on their income.

365 Umbrella Ltd

Details of persons 365 Umbrella Ltd

suspected of
promoting the
scheme

Addresses of 7 Jardine House, Bessborough Road, Harrow,

persons suspected HA1 3EX
of promoting the
scheme

Date of publication 6 June 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is The scheme users’ total remuneration for their
claimed to work contracts with 365 Umbrella Limited (3UL) is
artificially separated into 2 elements. The first
element is a salary with Income Tax and National
Insurance contributions (NICs) deducted. The
second element is sometimes referred to as
‘Grantee’s payments under a conditional annuity
purchase agreement’ and is made without the
deduction of Income Tax and NICs. 3UL claim that
the second element should not count as
employment income.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income / as the
considers relevant to users’ salary’ and therefore subject to Income Tax
publish about these and NICs. HMRC has previously published
schemes Spotlight 60 on disguised remuneration schemes
involving agency workers and contractors
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employed by umbrella companies. HMRC are

aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant scheme.
HMRC advise employees of 3UL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Ultra Employment Ltd

We have published 2 entries relating to schemes operated by Ultra
Employment Ltd:

entry 1 – published under the Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Details of persons Ultra Employment Ltd (UEL) / Mr Barry Aldridge

suspected of (Director of UEL)
promoting the
scheme, or of being a
connected person

Date of publication 11 April 2024

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The scheme users enter an employment contract

claimed to work with UEL and receive their remuneration by one of
3 payment methods, all of which mean tax and
National Insurance contributions (NICs) are only
paid on part of the entire remuneration for the
user’s services. The first method is a single
aggregated payment from UEL, made up of 2
elements, a salary with tax and NICs deducted,
and another without deductions. The second
method involves 2 separate payments to the
scheme user from UEL, a salary with tax and
NICs deducted, and another made without
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deductions. The third method is a salary paid by

UEL, with the other payment made by a third
party. UEL purport that the untaxed amounts are
for either a share growth in an Isle of Man cell
company, or other means that they maintain is not
related to employment income.

Any other HMRC have previously published Spotlights on

information HMRC disguised remuneration schemes involving
considers relevant to umbrella companies (Spotlight 45 and Spotlight
publish about these 60) based on similar arrangements. HMRC are
schemes aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant scheme.
HMRC advise employees of UEL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop
Notice has been
published

Date arrangements 6 February 2025

subject to Stop
Notice published

Date name of 6 February 2025

promoter subject to
Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a stop

notice

The Umbrella Agency Limited

Name of scheme The Umbrella Agency Annuity Option Scheme

Details of persons The Umbrella Agency Limited (TUA) / Stuart

suspected of John Brooke (director of The Umbrella Agency
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promoting the scheme, Limited) / Griffith Anderson Limited

or of being a
connected person

Addresses of The Umbrella Agency Limited: The Colmore

promoters suspected Building 20 Colmore Circus, Queensway,
of promoting the Birmingham, England, B4 6AT / Griffith
scheme Anderson Limited: 7 Bell Yard, London,
England, WC2A 2JR

Date of publication 31 August 2022

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve individuals providing

claimed to work – their services to end clients through TUA and
summary entering into an agreement that sees the
individual grant TUA an option on an Annuity
Agreement. The result is the remuneration for
their services is artificially separated into salary
as well as payments said to be in return for the
option. The payments in relation to the annuity
option are not subjected to tax and National
Insurance contributions.

Any other information The Scheme Reference Number 05565111 was

HMRC considers allocated to the arrangements on 3 August
relevant to publish 2022. The employing company, TUA, states that
about these schemes it simply acts as a payroll bureau and agent for
another company based in Malta under the
ultimate direction of the same director as the
employing company.

Umbrella Link Ltd

Details of persons Umbrella Link Ltd (ULL)

suspected of
promoting the
scheme

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Addresses of Lonsdale Gate, Lonsdale Gardens, Tunbridge

persons suspected Wells, TN1 1NU
of promoting the
scheme

Date of publication 13 February 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of ULL. Employees receive part of their
remuneration from ULL at a rate close to the
National Minimum Wage or National Living Wage
which is subjected to deductions for Income Tax
and National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deduction of Income Tax
or NICs, which ULL may suggest relates to the
reimbursement of expenses.

Any other HMRC’s view is that both elements of the

information HMRC employees pay should be treated as ‘normal
considers relevant to income/as the user’s salary’, and therefore subject
publish about these to Income Tax and NICs. HMRC have previously
schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and
contractors employed by umbrella companies.
ULL’s website advertises its services to those in
finance, healthcare, IT, Law, energy, transport,
media, and engineering. HMRC also has reason to
suspect that ULL target social workers. HMRC are
aware that some umbrella companies operate
more than one scheme, such as a standard
compliant scheme and a non-compliant scheme.

Umbrella Union Ltd

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Details of persons Umbrella Union Ltd (UUL)

suspected of
promoting the
scheme

Addresses of 9 Burns Street, Bootle L20 4RJ

promoters
suspected of
promoting the
scheme

Date of publication 10 October 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Employees of UUL receive part of their

claimed to work – remuneration as a salary, paid at or close to the
summary minimum rate permitted under the National
Minimum Wage Act 1998, that is subjected to
deductions for Income Tax and National Insurance
contributions (NICs). UUL Employees also receive
a secondary element of their remuneration that is
not subjected to the deduction of Income Tax
and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to tax and NICs.
to publish about HMRC have previously published Spotlight 60 on
these schemes disguised remuneration schemes involving agency
workers and contractors employed by umbrella
companies. HMRC are aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC advises employees of
UUL to familiarise themselves with the guidance
and to satisfy themselves that the correct amount
of tax is being deducted from their income.

Umbrella Zone Limited

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Details of persons Umbrella Zone Limited (UZL) / Ian Falconer

suspected of (Director of UZL)
promoting the
scheme, or of being a
connected person

Addresses of persons Gainsborough House, 59-60 Thames Street,

suspected of Windsor, SL4 1TX
promoting the
scheme

Date of publication 18 July 2024

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The scheme users’ total remuneration for their
claimed to work [employment] contracts with UZL is made in one
aggregate payment by UZL. This aggregate
payment is artificially separated into 2 elements.
The first element is a salary at a rate of National
Minimum Wage or National Living Wage with
Income Tax and National Insurance contributions
(NICs) deducted. The second element is made
without deduction of Income Tax and NICs by
UZL, even though this element also derives from
the users’ economic activities and should
therefore be treated as employment income.

Any other information It is HMRC’s view that all remuneration paid to

HMRC considers employees of UZL is employment income and
relevant to publish therefore taxable. HMRC have previously
about these schemes published guidance for agency workers and
contractors employed by umbrella companies
Spotlight 60.

United Pension Administration Ltd

Name of scheme NHMA Pension Benefits Scheme

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Details of persons United Pension Administration Ltd (UPA) /

suspected of Countryside Capital Ltd (CCL)
promoting the scheme

Addresses of persons United Pension Administration Ltd: 119060948-

suspected of Companies House Default Address, Cardiff,
promoting the scheme CF14 8LH / Countryside Capital Ltd: Whitefriars
Business Centre, 2nd floor, Whitefriars Lewins
Mead, Bristol, BS1 2NT

Date of publication 19 September 2024

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is An individual transfers funds from an existing

claimed to work pension scheme(s) into a bank account in the
name of UPA (A Trustee of the NHMA Pension
Benefits Scheme). UPA transfers the funds to
various limited companies including CCL. CCL
transfers part of the funds it receives to the
individual on the basis that it is claimed that the
payments would not need to be declared via
their Self Assessment returns.

Any other information HMRC advises users of this and similar

HMRC considers schemes that payments from pension funds as
relevant to publish described above should be declared via the
about these schemes individuals’ Self Assessment returns.

Universe Payroll Limited

We have published 2 entries that relate to a scheme operated by Universe
Payroll Limited:

entry 1 – published under Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

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Details of persons Universe Payroll Limited (UPL) / Brett

suspected of promoting Hardiman (Director of UPL) / Bonzai Umbrella
the scheme, or of being a Limited
connected person, or
having any other role in
relation to making the
scheme available for
implementation

Addresses of persons UPL: 7 Bell Yard, London, WC2A 2JR /

suspected of promoting Bonzai Umbrella Limited: 7 Bell Yard, London,
the scheme, or having WC2A 2JR
any other role in relation
to making the scheme
available for
implementation

Date of publication 13 March 2025

Legislation under which Finance Act 2022

this scheme/promoter
has been named

How the scheme is The arrangements involve scheme users

claimed to work providing their services to end clients as
employees of UPL. The scheme users receive
a single payment from UPL for services
provided to end clients made up of two
elements. The first element is a basic salary
at or around the rate of National Minimum
Wage or National Living Wage which is
subjected to Income Tax and National
Insurance contributions (NICs). The second
element is an amount that has not been
subjected to Income Tax and NICs. Bonzai
Umbrella Limited has made significant
payments to UPL. HMRC suspect this is in
respect of scheme users and that Bonzai
Umbrella Limited has a role in relation to
making the arrangements available for
implementation.

Any other information HMRC’s view is that both elements of the

HMRC considers relevant payment should be treated as ‘normal
to publish about these income/as the user’s salary’, and therefore
schemes subject to Income Tax and NICs. HMRC have
previously published Spotlight 60 on
disguised remuneration schemes involving
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agency workers and contractors employed by

umbrella companies. HMRC are aware that
some umbrella companies operate more than
one scheme, such as a standard compliant
scheme and a non-compliant scheme. HMRC
advise employees of UPL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is
being deducted on their income.

Scheme entry 2

Name of promoter Universe Payroll Limited

Date arrangements 17 October 2024

subject to Stop Notice
published

Date name of promoter 6 February 2025

subject to Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a

stop notice

Veqta Ltd

Name of scheme Veqta Remuneration Structure

Details of persons Veqta Ltd (Incorporated in Malta) – Offshore

suspected of Promoter / Stuart John Brooke (Director of Veqta
promoting the Ltd (Malta)) / Veqta Ltd (UK) – Onshore
scheme, or of being a Intermediary
connected person

Addresses of Veqta Ltd (Malta), 1, Floor 2, Falzun Street, C/W

promoters suspected Naxxar Road, Birkirkara, BKR1441, Malta /
of promoting the Veqta Ltd (UK), 20-22 Wenlock Road, London,
scheme N1 7GU

Date of publication 5 July 2023

Legislation under Finance Act 2022

which this
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scheme/promoter has
been named

How the scheme is Scheme users provide services to end clients

claimed to work – through Veqta Ltd (a Maltese company) and its
summary UK nominee and agent. The users enter into an
agreement that grants Veqta Ltd (Malta) an
option on an annuity agreement. The
remuneration for their services is artificially
separated into salary and payments said to be in
return for the option. The payments said to be in
relation to the annuity option are made without
the deduction of Income Tax and National
Insurance contributions.

Any other information HMRC have previously published information

HMRC considers about The Umbrella Agency Ltd, for which Stuart
relevant to publish John Brooke is also a director. HMRC has
about these schemes published Spotlight 35 in 2017 on disguised
remuneration schemes involving annuity
agreements, based on a predecessor
arrangement.

Vision HR Solutions Ltd

Name of scheme Vision HR Remuneration Structure

Details of persons Vision HR Solutions Ltd (Incorporated in Malta) –

suspected of Offshore Promoter / Stuart John Brooke (Director
promoting the of Vision HR Solutions Ltd (Malta)) / Vision
scheme, or of being a Human Resource Solution Ltd – UK Promoter
connected person

Addresses of Vision HR Solutions Ltd (Malta), 1, Floor 2,

promoters suspected Falzun Street, C/W Naxxar Road, Birkirkara,
of promoting the BKR1441, Malta / Vision Human Resource
scheme Solutions Ltd, 71-75 Shelton Street, London,
Greater London, WC2H 9JQ

Date of publication 5 July 2023

Legislation under Finance Act 2022

which this

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scheme/promoter has
been named

How the scheme is Scheme users provide services to end clients

claimed to work – through Vision HR Solutions Ltd (a Maltese
summary company) and Vision Human Resource Solutions
Ltd (its UK nominee and agent). The users enter
into an agreement that grants Vision HR
Solutions Ltd (Malta) an option on an annuity
agreement. The remuneration for their services is
artificially separated into salary and payments
said to be in return for the option. The payments
said to be in relation to the annuity option are
made without the deduction of Income Tax and
National Insurance contributions.

Any other information HMRC have previously published information

HMRC considers about The Umbrella Agency Ltd, for which Stuart
relevant to publish John Brooke is also a director. HMRC has
about these schemes published Spotlight 35 in 2017 on disguised
remuneration schemes involving annuity
agreements, based on a predecessor
arrangement.

Vision Human Resource Solutions Ltd

Name of promoter Vision Human Resource

Solutions Ltd (VHR UK)

Date arrangements subject to Stop 6 February 2025

Notice published

Date name of promoter subject to 6 February 2025

Stop Notice published

POTAS publication List of tax avoidance schemes

subject to a stop notice

Vortexx Limited

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Details of persons Vortexx Limited (Company number 15191526)

suspected of
promoting the
scheme

Addresses of Office One, 1 Coldbath Square, London, England,

persons suspected EC1R 5HL
of promoting the
scheme

Date of publication 13 February 2025

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Vortexx Limited. Employees receive
part of their remuneration at a rate close to the
National Minimum Wage or National Living Wage
which is subjected to deductions for Income Tax
and National Insurance contributions (NICs).
Employees receive the balance of their
remuneration without the deduction of Income Tax
or NICs.

Any other HMRC’s view is that both elements of the

information HMRC employees’ payment should be treated as ‘normal
considers relevant income/as the user’s salary’, and therefore subject
to publish about to Income Tax and NICs. HMRC have previously
these schemes published Spotlight 60 on disguised remuneration
schemes involving agency workers and contractors
employed by umbrella companies. HMRC are
aware that some umbrella companies operate more
than one scheme, such as a standard compliant
scheme and a non-compliant scheme. HMRC
advise employees of Vortexx Limited to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income. HMRC suspects that
employees within the social work and local authority
sectors have adopted the use of these
arrangements. These individuals are likely to be
employed through Vortexx Limited but are
undertaking work for local authorities.

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We Are Ava Limited

Details of persons We Are Ava Limited (WAA) (formerly Hunter State

suspected of Limited)
promoting the
scheme

Address of persons 61 Mosley Street, Manchester, M2 3HZ

suspected of
promoting the
scheme

Date of publication 16 May 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Hunter State Limited now trading as We Are Ava
claimed to work Limited (WAA) provide employment to scheme
users. WAA pay scheme users a salary close to the
National Minimum Wage or National Living Wage
rate with Income Tax and National Insurance
contributions (NICs) deducted. Scheme users also
receive a secondary payment from WAA described
as ‘Option’ or ‘additional’ amount that is paid
without Income Tax and NICs deducted. This
secondary payment is typically paid on the same
day as the salary payments. It is HMRC’s view that
all payments made to the scheme users are
taxable.

Any other HMRC do not accept these arrangements work as

information HMRC claimed, and Income Tax and NICs should be
considers relevant accounted for on the ‘Option’ or ‘additional’
to publish about payments. It is HMRC’s view that the 2-payment
these schemes arrangement is set up purely to facilitate a
disguised remuneration tax avoidance
scheme. HMRC is aware that some umbrella
companies operate more than one scheme, such
as a standard compliant scheme and a non-
compliant scheme. HMRC have previously
published information about the tax avoidance
arrangements used by some umbrella companies
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Spotlight 60. HMRC advise employees of WAA to

familiarise themselves with the guidance and to
satisfy themselves that the correct amount of tax is
being deducted on their income.

Whitebridge Management Ltd

We have published 2 entries that relate to one scheme operated by
Whitebridge Management Ltd:

entry 1 – published under the Finance Act 2022

entry 2 – published under Promoters of Tax Avoidance Schemes regime

Scheme entry 1

Details of persons Whitebridge Management Ltd (WML)

suspected of
promoting the
scheme

Addresses of 71-75 Shelton Street, London, England, WC2H

persons suspected 9JQ
of promoting the
scheme

Date of publication 8 August 2024

Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of WML. Employees receive part of
their WML remuneration at a rate close to the
National Minimum Wage or National Living Wage
which is subject to deductions for Income Tax and
National Insurance contributions (NICs).
Employees receive the balance of their
remuneration via another method which is paid to
them without the deduction of Income Tax and
NICs.

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Any other HMRC considers both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant to salary’, and therefore subject to Income Tax and
publish about these NICs. HMRC have previously published Spotlight
schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, such as a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of WML to familiarise themselves with
the guidance and to satisfy themselves that the
correct amount of tax is being deducted on their
income.

Scheme entry 2

Legislation under Promoters of Tax Avoidance Schemes (POTAS)

which this Stop
Notice has been
published

Date arrangements 6 February 2025

subject to Stop
Notice published

Date name of 6 February 2025

promoter subject to
Stop Notice
published

POTAS publication List of tax avoidance schemes subject to a stop

notice

Your Pay Ltd

Details of persons Your Pay Ltd (YPL) / Ronnie Welsh (sole director
suspected of of YPL)
promoting the
scheme, or of being a
connected person

Addresses of 71-75 Shelton Street, London, WC2H 9JQ

promoters suspected
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of promoting the
scheme

Date of publication 22 August 2024

Legislation under Finance Act 2022

which this
scheme/promoter has
been named

How the scheme is The arrangements involve users providing their

claimed to work services to end clients through YPL. The users
sign a contract of employment that will pay them
a basic salary at a rate close to the National
Minimum Wage or National Living
Wage. YPL then makes a single payment to the
user comprising 2 elements. The first element is
the salary, with Income tax and National
Insurance contributions (NICs) deducted, and the
second element is an additional amount
(described as a withdrawal) without Income Tax
or NICs deducted.

Any other information HMRC’s view is that both elements of the

HMRC considers payment should be treated as ‘normal income/as
relevant to publish the user’s salary’ and therefore, subject to Income
about these schemes Tax and NICs. HMRC have previously published
Spotlights on disguised remuneration schemes
involving umbrella companies Spotlight 45
Spotlight 60 based on similar arrangements.

Your PAYE Limited

Details of persons Your PAYE Limited

suspected of
promoting the
scheme

Addresses of Former address: 167-169 Great Portland Street,

persons suspected London, W1W 5PF / Current address: Floor 2, 10
of promoting the Wellington Place, Leeds, LS1 4AP
scheme

Date of publication 8 August 2024

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Legislation under Finance Act 2022

which this
scheme/promoter
has been named

How the scheme is Individuals provide services to end clients as

claimed to work employees of Your PAYE Limited. Some employees
of Your PAYE Limited receive part of their
remuneration as a salary paid at a rate close to the
minimum permitted under the National Minimum
Wage Act 1998 that is subjected to Income Tax and
National Insurance contributions (NICs). They also
receive a secondary element of their remuneration
that is not subjected to the deduction of Income Tax
and NICs.

Any other HMRC’s view is that both elements of the payment

information HMRC should be treated as ‘normal income/as the user’s
considers relevant salary’, and therefore subject to Income Tax and
to publish about NICs. HMRC have previously published Spotlight
these schemes 60 on disguised remuneration schemes involving
agency workers and contractors employed by
umbrella companies. HMRC are aware that some
umbrella companies operate more than one
scheme, for example a standard compliant scheme
and a non-compliant scheme. HMRC advise
employees of Your PAYE LimitedYPL to familiarise
themselves with the guidance and to satisfy
themselves that the correct amount of tax is being
deducted on their income.

3. If you’re involved in a tax avoidance

scheme
If you’re worried about becoming involved in a tax avoidance scheme, or
think you’re already involved and want to get out of one, HMRC is here to
help.

If you’re using any of the schemes shown on the lists or similar schemes,
HMRC strongly advises you to withdraw from them and settle your tax
affairs to prevent building up a large tax bill.

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If you’re already speaking to someone in HMRC about your use of a tax

avoidance scheme, you should contact them to discuss this further.

If you do not have an HMRC contact and you want to get out of a tax
avoidance scheme, contact HMRC
([Link]
avoidance-getting-out-of-an-avoidance-scheme).

Report a tax avoidance scheme to HMRC

You can report tax avoidance schemes and those offering you the schemes
to HMRC. You can do this by using the report tax fraud or avoidance online
service ([Link]

You can submit this form anonymously. You do not have to give your name,
address or email.

If you cannot use the online form, you can contact HMRC
([Link]
fraud-to-hmrc).

4. Details of how each named scheme is

claimed to work

Countrywide Partners Limited

1. Scheme users enter into an employment contract with Countrywide
Partners Limited (CPL). The contract states that the user will be paid a
salary equivalent to National Minimum Wage (NMW) or National Living
Wage (NLW) plus holiday pay. It also provides that any additional
payments will constitute as a ‘Bonus’.
2. Users will also enter into a ‘Bonus, Incentive or Pay Scheme Offer’ called
the ‘Bonus Agreement’ and a separate Loan Agreement with CPL. The
Loan Agreement states that CPL promises to loan certain monies,
secured against any ‘bonus’ payments, made to the user as pursuant to
the terms of the bonus agreement.
3. CPL invoice the recruitment agency or end user for the services carried
out by the scheme user. CPL retain 15% from the gross amount received.
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4. CPL pay the user:

the NMW or NLW salary and any holiday pay through the payroll with
Income Tax and National Insurance contributions deducted from these
earnings
the remaining balance is paid to the user in the form of a loan (that will
supposedly be repaid by future bonus payments) – bonus payments are
taxable income, but tax is not paid on the loans.

Saxonside Limited – Saxonside Share Growth

1. The scheme users enter into an employment contract with Saxonside
Limited (SAX) and are issued a share in the cell in Omni Contractors
Limited (OCP) that is unique to the scheme user.
2. Scheme users submit timesheets to SAX who then invoice the agency or
end client for the work done.
3. SAX retains approximately 10% of the invoiced amount, which is
allegedly for covering any capital gains tax (CGT) the scheme user may
be liable to in relation to the share. SAX claim they will return this amount
to the scheme user when their CGT liability is confirmed.
4. SAX retains a further amount of around 18% to 21% and pay the scheme
user a National Minimum Wage salary.
5. OCP pays the scheme user a separate amount without deductions for tax
and National Insurance contributions. This supposedly represents the
increased share value held in OCP.

5. Explanation of terms used

Accelerated Payment Notice (APN)

An APN is a requirement to pay an amount on account of tax or National
Insurance contributions. HMRC issues APNs to taxpayers involved in
avoidance schemes where an SRN has been allocated under the DOTAS
rules, or ones in respect of which HMRC has given a General Anti-Abuse
Rule counteraction notice. They can also be issued to taxpayers who have
received a follower notice in relation to a scheme.

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Authorised Officer
An authorised officer is a person that has been authorised by the
Commissioners for HMRC for the purpose of the 2022 legislation (section
86 Finance Act 2022). Only authorised officers can authorise the publication
of information under the section.

For the purposes of this legislation, authorised officers will be senior civil
servants and independent of any compliance activity relating to the tax
avoidance scheme in question.

Conduct notice
A conduct notice forms part of the POTAS regime. It is issued by HMRC and
imposes conditions on a promoter that must be complied with.

Connected persons
For the purposes of the 2022 legislation, a person is a connected person in
relation to a scheme, or to a promoter of a scheme, if the person is within
one of 5 specified categories. Read more information about connected
persons ([Link]
promoters-of-tax-avoidance-guidance/publication-by-hmrc-of-information-about-tax-
avoidance-schemes-section-86-part-6-finance-act-2022).

Enabler
Any person who is responsible, to any extent, for the design, management,
marketing or otherwise facilitating another person to enter into abusive tax
arrangements.

Entity

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A business entity is an organisation created to conduct business, engage in

a trade or partake in similar activities. For example, a ‘partnership’,
‘company’ or ‘limited liability partnership’.

Follower Notice
A follower notice can be given to a person who has used an avoidance
scheme that has been shown in another person’s litigation to be ineffective.
The follower notice tells the person they may be liable to a penalty of up to
30% of the tax and/or NICs in dispute if they do not amend their return or
settle their dispute.

Promoter
A person is a promoter if they are carrying on a business that includes, or
has included, the design, marketing, implementation, organisation or
management of tax avoidance schemes. A ‘person’ could be an individual,
company or partnership.

Scheme reference number (SRN)

A SRN is a number allocated to a tax avoidance scheme by HMRC at the
time the scheme is disclosed to them, or, where a scheme has not been
disclosed and HMRC reasonably suspect that the scheme should have
been disclosed. It allows HMRC to identify and track users of disclosed tax
avoidance schemes. The allocation of a SRN does not mean that HMRC
has in any way approved or cleared a scheme for use.

Stop Notice
Stop notices may be issued to a person who HMRC suspects is promoting
an avoidance scheme, which they consider does not work. If a promoter
does not comply with a stop notice they would meet a POTAS threshold
condition. This may lead to HMRC giving them a conduct notice.

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Monitoring notice
A monitoring notice forms part of the POTAS regime. It is issued by HMRC
where a promoter breaches a requirement in a conduct notice. A promoter
that is subject to a monitoring notice is referred to as a monitored promoter
and is subject to various disclosure requirements and other obligations and
a strict penalty regime where those requirements or obligations are not met.

Supplier
Supplier refers to persons involved in the supply of tax avoidance schemes.
‘Supplier’ includes promoters and also other suppliers who do not meet the
definition of promoter. There are many different ways a person may be
involved in the supply of the scheme.

All content is available under the Open Government Licence v3.0, except where otherwise stated © Crown copyright

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