HMRC Regularly updates a list of companies, promoters, enablers and suppliers of Tax Avoidance Schemes on their website.
HMRC will remove a company after one year, whereas we don’t.
We have provided the historic entries as well as current ones in a searchable list below for your ease.
Showing all 238 entries
| Date named | Company or scheme | Company number | Status | Details |
|---|---|---|---|---|
| 20 August 2026 | MUE Admin HR Ltd | 16766036 | Currently named | |
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Address MAHR: 45-55 Commercial Street, London, E1 6BD Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve scheme users providing their services to ‘end users’ as employees of MAHR. Employees of MAHR receive part of their remuneration as a salary, paid at a rate significantly below what they were paid in their previous employment, and this element of their pay is subjected to deductions of Income Tax and National Insurance contributions (NICs). HMRC suspects that MAHR employees also receive a secondary element of their remuneration that is paid to them without deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employee’s pay should be treated as earnings from employment, and therefore subject to Income Tax and NICs. HMRC advises employees of MAHR to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 20 August 2026 | Novara Nexus Ltd | 16011023 | Currently named | |
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Address NNL: Collingwood Buildings, 38 Collingwood Street, Newcastle Upon Tyne, United Kingdom, NE1 1JF / APP: Business Technology Centre, Bessemer Drive, Stevenage, SG1 2DX Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients as employees of NNL. APP act in collaboration with NNL by engaging with employment intermediaries. APP receive payments on behalf of work carried out by NNL’s employees and then forward those payments to NNL, who ultimately operate the payroll for the arrangements. NNL declares a portion of the employees’ earnings through Pay As You Earn (PAYE) and deducts Income Tax and National Insurance contributions (NICs). This rate of pay is often at, or close to, National Minimum Wage (NMW) or National Living Wage (NLW). The balance of the employees’ earnings is paid without the deduction of Income Tax and NICs. These payments may be described as a ‘loan’, advance’, or ‘discretionary profit-sharing bonus’.
Other information from HMRC
HMRC’s view is that both elements of the NNL employees’ pay should be treated as earnings from employment and therefore subject to Income Tax and NICs. HMRC advise employees of NNL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. NNL appears to target employees within the Council/Local authority sector for participation in the arrangements.
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| 13 August 2026 | Chartian Management Ltd | 13875998 | Currently named | |
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Address CML: Kemp House, 160 City Road, London, EC1V 2NX / Echo Pay Limited: Suite 20b Unit 3 Q Estate, Melton Road, Queniborough, Leicester, LE7 3FP / UCSL: Suite 8k Trigg House, Warren Drive, Prestatyn, Wales, LL19 7HT Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve scheme users providing their services to end clients as employees of CML. CML receives payments from end clients and recruitment agencies, and issues contracts of employment to scheme users. CML then pays UCSL, who in turn makes payments to the scheme users. The users are 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 an additional payment described as a ‘withdrawal amount’ without deductions for Income Tax and NICs. Echo Pay Limited file the Real Time Information PAYE returns associated with the users of the arrangements. CML, Echo Pay Limited and UCSL were allocated the scheme reference number (SRN) 22259913 on 10 March 2026.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as employment income, and 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.
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| 13 August 2026 | Merium Limited | 15889092 | Currently named | |
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Address Merium Limited: 4th Floor, Silverstream House, 5 Fitzroy Street, Fitzrovia, London, W1T 6EB Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients as employees of Merium Limited. Merium Limited declares a portion of the employees’ earnings through Pay as You Earn (PAYE) and deducts Income Tax and National Insurance contributions (NICs). This rate of pay is often at or close to National Minimum Wage (NMW) or National Living Wage (NLW). The balance of the employees’ earnings is paid without the deduction of Income Tax and NICs. This payment may be described as a ‘loan’ or ‘advance’.
Other information from HMRC
HMRC’s view is that the untaxed payments made by Merium Limited 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 Merium Limited 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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| 13 August 2026 | Nebulix Ltd | 15571752 | Currently named | |
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Address NL (former address): 50 Princes Street, Ipswich, Suffolk IP1 1RJ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of NL. Employees receive part of their NL 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of NL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 30 July 2026 | Freeteam Ltd | 16105388 | Currently named | |
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Address 128 City Road, London, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide services to end clients as employees of FL. Employees receive part of their FL 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 and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC has reason to suspect that FL users are working in councils and NHS Trusts. 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 FL to familiarise themselves with the Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 30 July 2026 | Kimson Accountancy Limited | 12593550 | Currently named | |
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Address Unit 1-3 Salisbury Street, Widnes, England, WA8 6PJ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients via their own personal service company (PSC) as deemed employees of Kimson Accountancy Limited. Part of their remuneration is paid to their PSC at a rate close to the National Minimum Wage or National Living Wage which is subjected to deductions of Income Tax and National Insurance contributions (NICs). The balance of their remuneration is paid without the deduction of Income Tax or NICs via a company based in the Isle of Man and is described as a dividend.
Other information from HMRC
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 users of Kimson Accountancy Limited’s services to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. Users should also be vigilant to the risks posed by new service providers they transfer to; particularly those recommended by Kimson Accountancy Limited or their associates.
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| 30 July 2026 | Vantage4 Limited | 16295648 | Currently named | |
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Address 176 Ashley Road, Poole, BH14 9BY Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide services to end clients as employees of Vantage4 Limited (“VL”). Employees receive part of their VL 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 as it is claimed to not count as employment income.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously published Spotlight 60 on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies. HMRC has reason to suspect that VL users are working in councils and NHS Trust. 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 VL 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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| 2 July 2026 | Buckingham Administration Co. Ltd | — | Currently named | |
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Address Buckingham Administration Co. Ltd: No.1 Orchid Garden Street, Belmopan, Belize / Belize Offshore Services Limited: No.1 Orchid Garden Street, Belmopan, Belize / St Guaden & Associates Limited: No.1 Orchid Garden Street, Belmopan, Belize / GCWealth Administrators Limited: C/O Belize Offshore Services Limited, Suite 5 Garden City Plaza, Mountainview Boulevard, Belmopan, Belize Named under Finance Act 2022
How the scheme is claimed to work
A scheme user (for example a company or self-employed person) contributes to an offshore trust (the Buckingham Administration Co. Ltd Nova Trust 1, the GCWealth Administration LLC Nova Trust 1 or some other trust) and claims the contribution as a deductible Corporation Tax or Income Tax expense. If the user is a company, the money claimed to have been contributed to the Trust is subsequently transferred to the company’s director, typically via another company they are a director and/or shareholder of. The director or self-employed person claims to have received this money from the trust either by way of loans, or to be holding it in a fiduciary capacity. No Income Tax or National Insurance contributions (NICs) are paid by the director or the self-employed person on amounts they claim to receive from the trust.
Other information from HMRC
Nova Trust deeds include a provision with the claimed effect that any enquiries into the scheme from HMRC will cause the trust to be void from the outset. In promotional material, it is claimed that its assets are deemed to be settled on another new trust with the same self-voiding provision, and that HMRC would have to open a new enquiry. HMRC considers this claim to be incorrect and open enquiries into an individual or company remain valid. It is HMRC’s view that the arrangements involving Nova Trusts are a continuation of the Remuneration Trust arrangements published by HMRC under Finance Act 2022 on 3 May 2023. Contributions to Nova Trusts are not allowable deductions for Income Tax or Corporation Tax purposes and funds received from the trust or retained by the user, or its directors, employees or others, are taxable as earnings. Recent tribunal decisions support this view (see Spotlight 61).
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| 11 June 2026 | Arka Wealth OU | — | Currently named | |
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Address Arka Wealth OU registered office: Harju maakond, Tallinn, Põhja-Tallinna linnaosa, Saani tn 2/2-26, 10149 Named under Finance Act 2022
How the scheme is claimed to work
The company transfers all its intellectual property to a ‘Cyprus International Trust’. The company then pays the trust for the use of intellectual property. When the owner of the company wants to purchase a sizeable asset, such as a house, the trust buys it for them and lets them use it. For everyday living expenses, the owner of the company draws money from the trust as a loan. It is claimed that the trust is exempt from all tax, and the company and its owners do not have taxable income; however, it is HMRC’s view that the money drawn from the trust and assets purchased, on behalf of the company or its owner, is subject to UK tax.
Other information from HMRC
These schemes were actively marketed by the named entities and individuals who targeted potential users through extensive social media and websites.
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| 4 June 2026 | Pay Point Services Limited | 16337089 | Currently named | |
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Address Unit 1-3 Salisbury Street, Widnes, WA8 6PJ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of PPSL. Employees receive part of their remuneration from PPSL 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC suspects that the arrangement is targeted at healthcare professionals. HMRC advise employees of PPSL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 30 April 2026 | Atlas Outflows Limited | — | Currently named | |
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Address AOL registered office: PO Box 2775,71 Fort Street, 3rd Floor, Grand Cayman, Cayman Islands / AOL business/correspondence address: John Lancaster House, Main Road, Crosby, Isle of Man, IM4 4BN / IUL registered address: Initial Business Centre, Wilson Business Park, Manchester, M40 8WN Named under Finance Act 2022
How the scheme is claimed to work
HMRC suspect scheme users sign a contract of employment and a secondary agreement with AOL, a company based in the Cayman Islands. AOL utilise the support of a UK umbrella company called IUL, who enter into an agreement for administrative services with AOL. IUL then contract the scheme user’s services to an end client, sometimes via an intermediary/agency. The end client pays the intermediary/agency for the scheme user’s services, who in turn pay IUL. IUL pay AOL who then pay a salary to the scheme users, at the minimum rate permitted under the National Minimum Wage Act 1998, with Income Tax and National Insurance contributions (NICs) deducted. AOL also make a second payment to the scheme users, described as a loan and made pursuant to the secondary agreement, without deductions of Income Tax and NICs.
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| 9 April 2026 | Wiz Systems Limited | 15560493 | Currently named | |
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Address Suite 20b, Unit3, Q Estate, Melton Road, Queniborough, LE7 3FP Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of WSL. Some employees of WSL 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 subject to deductions for Income Tax and National Insurance contributions (NICs). These employees also receive a secondary element of their remuneration that is paid without the deduction of Income Tax and NICs.
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| 26 March 2026 | Umbrella Requirements Ltd | 08184119 | Currently named | |
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Address URL: Grosvenor St Pauls, St. Pauls Square, Birmingham, B3 1RB / BWM: Cromwell House, Ground Floor, 117 Albert Street, Belize City, Belize — also, Suite 11, Penhurst House, 352-356 Battersea Park Road, London, SW11 3BY / PASL: Cromwell House, Ground Floor, 117 Albert Street, Belize City, Belize — also, Room 19, 70 West Regent Street, Glasgow, G2 2QZ Named under Finance Act 2022
How the scheme is claimed to work
Scheme users sign an employment contract with URL. URL invoice the end clients and agencies for the provision of the scheme users’ services. URL then pays the scheme users a salary at about the rate of National Minimum Wage (NMW) with Income Tax and National Insurance contributions (NICs) deducted. On or around the same day, BWM make a larger payment to scheme users. This payment is said to be made on behalf of a trust administered by PASL but without the deduction of Income Tax and NICs. It is HMRC’s view that the payment made by BWM is part of the remuneration for the scheme users services and should be subject to income tax and NICs.
Other information from HMRC
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 URL 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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| 24 March 2026 | Invictapay Ltd | 14935984 | Currently named | |
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Address Unit 1-3 Salisbury Street, Widnes, WA8 6PJ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of IVL. Employees receive part of their IVL remuneration at a rate close to the National Minimum Wage or National Living Wage which is subjected to deductions of Income Tax and National Insurance contributions (NICs). Employees receive the balance of their remuneration without the deduction of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 IVL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 19 March 2026 | KHRP Group Limited | 15231411 | Currently named | |
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Address KHRP: 5 Brayford Square, London, E1 0SG Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as employees of KHRP. Some employees of KHRP receive part of their remuneration, paid at or close to the rate of National Minimum Wage as a salary that is subjected to Income Tax and National Insurance contributions (NIC’s). The employees also receive a second element of their remuneration without deductions of Income Tax and NIC’s.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of KHRP to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 19 March 2026 | Oak Umbrella Ltd | 13470246 | Currently named | |
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Address OUL: Suite 174 Unit 1 Imperial Court, Exchange Street East, Liverpool L2 3AB Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of OUL. Employees receive part of their OUL 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of OUL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 19 March 2026 | Pro Act HR Ltd | 16309731 | Currently named | |
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Address Pro Act HR Ltd: 101 King’s Cross Road, London, WC1X 9LP Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve scheme users providing their services to ‘end users’ as employees of PAHR. Employees of PAHR receive part of their remuneration as a salary, paid at a rate significantly below what they were paid by previous employers, and this element of their pay is subjected to deductions of Income Tax and National Insurance contributions (NICs). HMRC suspects that PAHR employees also receive a secondary element of remuneration that is paid to them without deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employee’s pay should be treated as earnings from employment, and therefore subject to Income Tax and NICs. HMRC advises employees of PAHR to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 12 March 2026 | Finsgate Contracting Limited | 15924602 | Currently named | |
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Address 51 First Avenue, Canvey Island, SS8 9LR Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients as employees of FCL. 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 of their pay without deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the payment should be treated as earnings from employment, and therefore subject to Income Tax and NICs. HMRC advise employees to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. FCL appears to target employees within the healthcare sector and NHS workers for participation in the arrangements.
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| 19 February 2026 | Outsource Limited | — | Currently named | |
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Address OL: 2nd Floor, Bubble at Clinch’s, Lord Street, Douglas, Isle of Man, IM1 4LN / Inspired Umbrella Limited: Initial Business Centre, Wilson Business Park, Manchester, England, M40 8WN / Imagine Umbrella Limited (in liquidation) (former address): Piccadilly Business Centre, Unit C Aldow Enterprise Park, Manchester, M12 6AE / Total Payment Solutions Limited: International House, 307 Cotton Exchange, Old Hall Street, Liverpool, L3 9LQ / PUL: International House, 22-28 Wood Street, Doncaster, DN1 3LW Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Scheme users sign a ‘contract of employment’ and a ‘commercial loan agreement’ with OL, a company based in the Isle of Man. A UK umbrella company, either Inspired Umbrella Limited, Imagine Umbrella Limited, Total Payment Solutions Limited or Penguin Umbrella Limited (the ‘UK Umbrella Company’), then enters into an Agreement for Administrative Services with OL. The UK Umbrella Companies then contract the scheme user’s services to an end client, sometimes via an intermediary/agency. The end client pays the intermediary/agency for the scheme user’s services, who in turn pay the UK Umbrella Company. The UK Umbrella Company pay OL who then pay a salary at the minimum rate permitted under the National Minimum Wage Act 1998, to the scheme users with Income Tax and National Insurance contributions (NICs) deducted. OL also make a second payment to the scheme users, described as a loan and made pursuant to the loan agreement, without deductions of Income Tax and NICs.
Other information from HMRC
Imagine Umbrella Limited was involved with another known avoidance scheme, Compas Limited, published on 22 May 2025.
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| 12 February 2026 | HR Liquid Ltd | SC763092 | Currently named | |
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Address HR Liquid Ltd: (Former address:) 2/1 24 Sandyford Place, Glasgow, G3 7NG Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve scheme users providing their services to ‘end users’ as employees of HR Liquid Ltd. Employees of HR Liquid 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, that is subjected to deductions for Income Tax and National Insurance contributions (NICs). HMRC suspects that HR Liquid Ltd employees also receive a secondary element of their remuneration that is paid to them without deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employee’s pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advises employees to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 12 February 2026 | Signature Contracting Limited | 15606126 | Currently named | |
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Address SCL: 37 Mill Green Place, Pitsea, Basildon, SS13 3QU Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients as employees of SCL. 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 of their pay without deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of SCL employee pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. SCL appears to target employees within the healthcare sector and NHS workers for participation in the arrangements.
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| 15 January 2026 | MUE Admin Ltd | SC813275 | Currently named | |
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Address MUE: (Former address) 2/1 24 Sandyford Place, Office 5, Glasgow, G3 7NG Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve scheme users providing their services to ‘end users’ as employees of MUE. Employees of MUE 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). HMRC suspects that MUE employees also receive a secondary element of their remuneration that is paid to them without deductions for Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employee’s pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advises employees of MUE to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 15 January 2026 | Paylion Limited | SC831944 | Currently named | |
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Address 5 South Charlotte Street, Edinburgh, Scotland, EH2 4AN Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Paylion Limited. Employees receive part of their remuneration from Paylion Limited 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of Paylion Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 15 January 2026 | Zorbex Limited | 15538796 | Currently named | |
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Address Zorbex Limited: 46 Newark Close, Liverpool, England, L36 8JD Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Zorbex 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 of Income Tax and National Insurance contributions (NICs). Employees receive the balance of their remuneration without the deduction of Income Tax or NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of Zorbex Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. Some of the individuals employed through Zorbex Limited work within the health care and social work sectors, and undertake work for parties such as: NHS, care/nursing homes or local authorities.
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| 16 December 2025 | Only Best Limited | 13558067 | Currently named | |
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Address Only Best Limited: (Former address) Suite 2a Blackthorn House, St Paul’s Square, Birmingham, B3 1RL / Acquda Limited: (Former address) 45-55 Commercial Street, London, E1 6BD / Miwsa Limited: (Former address) Suite 03, 5 Wandsworth Road, Perivale, London, UB6 7JD / Balance Bay Limited: (Former address) Office 5272, 321-323 High Road, Romford, RM6 6AX / Employe Limited: (Former address) 50 Princes Street, Ipswich, IP1 1RJ / Payroll Pros Limited: (Former address) Suite 500b, 90-92 Butt Road, Part Fifth Floor, Annexe, Wellington House, Colchester, CO3 3DA / Five Payroll Solutions Ltd, Office 202, Cavell House, Stannard Place, St Crispins Road, Norwich, NR3 1YE / Clickpay Solutions Ltd, Suite 02, 3rd and 4th Floor, Franciscan House, Princes Street, Ipswich, IP1 1UR / Click Pay Solutions Management Ltd, Jubilee House, 3 The Drive, Brentwood, Essex, CM13 3FR / Payloc Limited, Office 209, 4 Imperial Place, Maxwell Road, Borehamwood, WD6 1JN / Levelup Payroll Ltd: (Former address) 32b Cambridge Road, Sawbridgeworth, Essex, CM21 9BU / Level Up Associates Limited: (Former address) 7 Bell Yard, London, WC2A 2JR Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide their services to end clients as employees of umbrella companies. The users get paid a salary at or around the rate of National Minimum Wage or National Living Wage with deductions for Income Tax and National Insurance contributions (NICs), and a second payment without deductions of Income Tax and NICs. Recruitment agencies paid money to OBL for the users’ services, and OBL in turn paid this money to the umbrella companies. The umbrella companies are: Acquda Limited, Miwsa Limited, Balance Bay Limited, Employe Limited Payroll Pros Limited, Five Payroll Solutions Ltd, Clickpay Solutions Ltd, Click Pay Solutions Management Ltd, Payloc Limited, Levelup Payroll Ltd, and Level Up Associates Limited.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. Several of the umbrella companies named in this publication are also linked to other arrangements involving Aura PAYE Limited and Workplace Wizards Limited. HMRC advise employees to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. OBL appears to target employees within the social work and local authority sectors for participation in the arrangements.
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| 16 December 2025 | Workplace Wizards Limited | 14708492 | Currently named | |
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Address Workplace Wizards Limited: Suite 05, 70-72 The Havens, Ransomes Europark, Ipswich, IP3 9BF / Balance Bay Limited: (Former address) Office 5272, 321-323 High Road, Romford, RM6 6AX / Employe Limited: (Former address) 50 Princes Street, Ipswich, IP1 1RJ / Levelup Payroll Ltd: (Former address) 32b Cambridge Road, Sawbridgeworth, Essex, CM21 9BU / Level Up Associates Limited: (Former address) 7 Bell Yard, London, WC2A 2JR Named under Section 86 Finance Act 2022
How the scheme is claimed to work
Scheme users provide their services to end clients as employees of umbrella companies. The users get paid a salary at or around the rate of National Minimum Wage or National Living Wage with deductions for Income Tax and National Insurance contributions (NICs) and a second payment without deductions of Income Tax and NICs. Recruitment agencies paid money to WWL for the scheme user’s services, and WWL in turn paid this money to several umbrella companies. The umbrella companies are: Employe Limited, Balance Bay Limited, Levelup Payroll Ltd, and Level Up Associates Limited.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. Several of the umbrella companies named in this publication are also linked to other arrangements involving Aura PAYE Limited and Only Best Limited. HMRC advice employees to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. WWL appears to target employees within the social work and local authority sectors for participation in the arrangements.
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| 11 December 2025 | Acuity Professional Advisers Ltd | 04938182 | Currently named | |
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Address APAL: Unit 2.02 High Weald House, Glovers End, Bexhill, TN39 5ES / CAL: 166 College Road, Harrow, HA1 1RA / MJAL: Suite 2 The Brentano Suite, Solar House, 915 High Road, London, N12 8QJ Named under Finance Act 2022
How the scheme is claimed to work
These arrangements are made available for implementation by CAL and APAL. The individual landlords incorporate their business as an LLP. The landlord transfers their rental properties, often with substantial accrued capital gains, to the LLP at market value. After a short period, the LLP is put into Members’ Voluntary Liquidation (MVL) usually with MJAL as the liquidator. The properties are then sold to a limited company owned by the landlord or connected parties. The promoters of this scheme claim that no CGT is payable on the transfer of the properties to the LLP on the difference between their original cost and market value at that time. On the disposal of the properties by the LLP, there is a tax-free uplift, and CGT is only payable on any increase value while the properties were owned by the LLP.
Other information from HMRC
With effect for MVLs entered into on or after 30 October 2024, s59AA, Taxation of Chargeable Gains Act 1992 applies with the result that the individual is treated as having disposed of the properties for CGT purposes immediately before the transfer to the LLP. This makes sure that members of an LLP that contribute assets to an LLP that liquidates in favour of the member, or a person connected to them, are taxed on the gains arising before the asset was contributed to the LLP. Therefore, these arrangements would no longer achieve the tax advantage due to this change in legislation.
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| 11 December 2025 | Aura PAYE Limited | — | Currently named | |
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Address Aura PAYE Limited (in liquidation): (Former address) 30 Newman Street, London, W1T 1PT / Acquda Limited (in liquidation): (Former address) 45-55 Commercial Street, London, E1 6BD / Miwsa Limited (in liquidation): (Former address) Suite 03, 5 Wandsworth Road, Perivale, London, UB6 7JD / Balance Bay Limited (in liquidation): (Former address) Office 5752, 321-323 High Street, Romford, RM6 6AX / Employe Limited (in liquidation): (Former address) 50 Princes Street, Ipswich, IP1 1RJ / Sphere Salaries Limited (in liquidation): Ash House Business Centre, 8 Second Cross Road, Twickenham, TW2 5RF / Quickconnect Workforce Limited (formerly called Bosworth Solutions Ltd): 30 Willow Street, Accrington, BB5 1LP (Former address: Damaz Building Suite 2, 18 Sharp Street, Manchester, M4 4BZ) / Five Payroll Solutions Ltd: Office 202, Cavell House, Stannard Place, St Crispins Road, Norwich, NR3 1YE / Clickpay Solutions Ltd: Suite 02, 3rd and 4th Floor, Franciscan House, Princes Street, Ipswich, IP1 1UR / Click Pay Solutions Management Ltd: Jubilee House, 3 The Drive, Brentwood, Essex, CM13 3FR / Levelup Payroll Ltd: Former Address 32b, Cambridge Road, Sawbridgeworth, Essex, CM21 9BU / Level Up Associates Limited: (Former address) 7 Bell Yard, London WC2A 2JR / Payloc Limited, Office 209, 4 Imperial Place, Maxwell Road, Borehamwood, WD6 1JN Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide their services to end clients as employees of umbrella companies. The users get paid a salary at or around the rate of National Minimum Wage or National Living Wage with deductions for Income Tax and National Insurance contributions (NICs), and a second payment without deductions of Income Tax and NICs. Money is paid to Aura PAYE Ltd for the users’ services, and Aura PAYE Limited in turn paid this money to the umbrella companies. The umbrella companies are: Employe Limited, Miwsa Limited, Acquda Limited, Balance Bay Limited, Sphere Salaries Limited, Bosworth Solutions Ltd, Five Payroll Solutions Ltd, Clickpay Solutions Ltd, Click Pay Solutions Management Ltd, Levelup Payroll Ltd, Level Up Associates Limited, and Payloc Limited.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. Several of the umbrella companies named in this publication are also linked to other arrangements involving Only Best Limited and Workplace Wizards Limited. HMRC advise employees to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. Aura PAYE Ltd appears to target employees within the healthcare sector and NHS workers for participation in the arrangements.
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| 11 December 2025 | Eagle Pay Limited | 15967783 | Currently named | |
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Address Eagle Pay Limited: Level One, Basecamp Liverpool, 49 Jamaica Street, Liverpool, L1 0AH Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Eagle Pay Limited. Employees receive part of their EPL 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary, and therefore subject to Income Tax and NICs. HMRC advise employees of EPL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 11 December 2025 | Engage Limited | — | Currently named | |
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Address Engage Limited: 20 Castle Court, Farrants Way, Castletown, Isle of Man, IM9 1PE / Previous registered address of IUL: Initial Business Centre, Wilson Business Park, Manchester, M40 8WN Named under Finance Act 2022
How the scheme is claimed to work
The scheme users sign a Contract of Employment and Commercial Loan Agreement with Engage Limited (EL), a company based in the Isle of Man. A UK umbrella company, Inspired Umbrella Ltd (IUL), then enters into an ‘Agreement for Administrative Services’ with EL and 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 IUL. IUL then invoice EL to obtain a fee for their services. IUL then send the money for the scheme user’s services to EL. EL pays the scheme users a National Minimum Wage /National Living Wage rate salary with Income Tax and National Insurance Contributions (NICs) deducted, and a payment, described as a loan, pursuant to the ‘Loan Agreement’, which is made without deductions of Income Tax or NICs.
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| 11 December 2025 | Jadecourt Limited | 15933674 | Currently named | |
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Address JL: The Balance, 2 Pinfold Street, Sheffield, S1 2GU Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of JL. Employees receive part of their JL remuneration at a significantly reduced rate 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.
Other information from HMRC
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 Jadecourt Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 11 December 2025 | Kingsborough Enterprises Limited | — | Currently named | |
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Address Kingsborough Enterprises Limited: Tower 42, 25 Old Broad Street, London, EC2N 1HN / Forward Management Services: FZE, Block C1 Office B C, 1300021, Ajman, United Arab Emirates / Haven Management Services: FZC, Block E1, SM Office E1, 4109E, Ajman, United Arab Emirates / Astus Recruitment Limited: Room 1014, Star House, 3 Salisbury Road, Tsim Sha Tsui, Hong Kong Named under Finance Act 2022
How the scheme is claimed to work
HMRC suspects individuals provide their services to end clients as employees of Mini Umbrella Companies (MUC). The MUC enters into agreements with KEL to provide KEL with contractors. Employment agencies or end clients pay KEL for these services and KEL pay the MUC for the same. The MUC pays employees a portion of these amounts as a salary and deduct Income Tax and National Insurance contributions (NICs). Further amounts are paid by the MUC to AR, FMS and HMS. The employee then receives an additional payment without deductions of Income Tax and NICs from Contractor Tap (CTAP). These amounts are claimed to be connected to a management company set up on behalf of the individual and as a result of the growth of a European Consultancy Network. HMRC suspects the money used for the additional payment is linked to the payments made by the MUC to AR, FMS and HMS.
Other information from HMRC
It is HMRC’s view that the additional payment made by CTAP to employees of the MUCs is remuneration for services provided by the employees and should be subject to Income Tax and National Insurance. HMRC have previously published Spotlight 60 guidance on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies. HMRC have also published information on MUCs, which sets out some of the characteristics typical of an MUC that may be present as part of these arrangements. HMRC are aware that some umbrella companies operate more than one scheme, for example a standard compliant scheme and a non-compliant scheme. HMRC advises all employees of MUCs who receive payments from CTAP to familiarise themselves with the guidance and satisfy themselves that the correct amount of tax is being deducted on their income.
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| 11 December 2025 | Magna Limited | — | Currently named | |
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Address ML: 2nd Floor, Bubble at Clinch’s, Lord Street, Douglas, Isle of Man, IM1 4LN / IUL (in liquidation): (former address) Piccadilly Business Centre, Unit C Aldow Enterprise Park, Manchester, M12 6AE / TPSL: International House, 307 Cotton Exchange, Old Hall Street, Liverpool, L3 9LQ / PUL: International House, 22-28 Wood Street, Doncaster, DN1 3LW Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Scheme users sign a ‘contract of employment’ and a ‘commercial loan agreement’ with ML, a company based in the Isle of Man. A UK umbrella company, either Imagine Umbrella Limited, Total Payment Solutions Limited or Penguin Umbrella Limited (the ‘UK Umbrella Company’), then enters into an Agreement for Administrative Services with ML. The UK umbrella companies then contract the scheme user’s services to an end client, sometimes via an intermediary/agency. The end client pays the intermediary/agency for the scheme user’s services, who in turn pay the UK umbrella company. The UK umbrella company pay ML who then pay a salary at the minimum rate permitted under the National Minimum Wage Act 1998, to the scheme users with Income Tax and National Insurance contributions (NICs) deducted. ML also make a second payment to the scheme users, described as a loan and made pursuant to the loan agreement, without deductions of Income Tax and NICs.
Other information from HMRC
IUL was involved with another known avoidance scheme, Compas Limited, published on 22 May 2025.
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| 11 December 2025 | Revolve Limited | — | Currently named | |
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Address RL: 2nd Floor, Bubble at Clinches, Lord Street, Douglas, Isle of Man, IM1 4LN / Previous registered address of IUL: Initial Business Centre, Wilson Business Park, Manchester, M40 8WN Named under Finance Act 2022
How the scheme is claimed to work
The scheme users sign a ‘Contract of Employment’ and ‘Commercial Loan Agreement’ with RL, a company based in the Isle of Man. A UK umbrella company Inspired Umbrella Ltd (IUL), then enters into an ‘Agreement for Administrative Services’ with RL. IUL 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 IUL. IUL then invoice RL to obtain a fee for their services. IUL then send the money for the scheme user’s services to RL. RL pays the scheme users a National Minimum Wage/National Living Wage rate salary with Income Tax and National Insurance contributions (NICs) deducted, and a payment, described as a loan, pursuant to the loan agreement, which is made without deductions of Income Tax or NICs.
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| 11 December 2025 | Simply PAYE Limited | 11481715 | Currently named | |
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Address Simply PAYE Limited: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Simply PAYE Limited offer their services to employers as payroll agents. Employees of Simply PAYE Limited’s clients sign a ‘Zero Hours Casual Worker Agreement’ with their employer, which confirms that their pay will be handled by an outsourced payroll service under PAYE. The employees also agree to Simply PAYE Limited’s ‘Agreement Terms’, which confirms that Simply PAYE Limited has been appointed to manage their payroll. Simply PAYE Limited process employees’ tax claims on work-related expenses that haven’t been reimbursed. Simply PAYE Limited does this by deducting those expenses from employees’ gross pay before tax is calculated. Simply PAYE Limited then reports the reduced gross pay amount to HMRC through PAYE. For this service, Simply PAYE Limited charges a ‘Processing Fee ‘ of up to 5.76% of the employees’ expenses they handled. Employees are usually paid for any holiday they have earned but not taken. However, Simply PAYE Limited may not include this holiday pay when calculating the employee’s gross pay.
Other information from HMRC
Simply PAYE Limited’s target market is the security services sector. Simply PAYE Limited may advertise significant purported tax savings from their payroll services compared to traditional PAYE. Simply PAYE Limited may offer a variety of ‘split’ options, each with varying employer and employee savings. HMRC’s view is that employers should not provide relief to employees at source for unreimbursed employment expenses by making deductions from their gross pay. HMRC have recently published further information on claiming expenses as part of a ‘Don’t get caught out’ campaign. Employers pay Secondary Class 1 NICs on their employees’ earnings. Simply PAYE Limited may include a portion of Secondary Class 1 National Insurance contributions (NICs, known as ‘employer NICs’) in the ‘Admin Charge’ deducted from employees’ gross pay. This balance of Secondary NICs is unlikely to be clearly displayed on employees’ payslips. Employer NICs should not be passed on to employees through a deduction in gross pay.
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| 4 December 2025 | Albury Hills Ltd | 13997937 | Currently named | |
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Address Albury Hills Ltd: Casa Court, Great George Street, Godalming, GU7 1DX Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as employees of Albury Hills Ltd. Albury Hills Ltd pay scheme users for their services via payment made up of 2 elements. The first element is a salary paid at the minimum rate permitted under the National Minimum Wage Act 1998 which is subject to deductions for Income Tax and National Insurance contributions (NICs). The second element is paid to scheme users without the deduction of Income Tax or NICs.
Other information from HMRC
HMRC have previously published a Spotlight on agency workers and contractors employed by umbrella companies Spotlight 60.
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| 4 December 2025 | APLO SVCS Limited | SC831943 | Currently named | |
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Address APLO SVCS Limited: 5 South Charlotte Street, Edinburgh, Scotland, EH2 4AN Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as employees of APLO SVCS Limited. Some employees of APLO SVCS Limited receive part of their remuneration, paid at or close to the rate of National Minimum Wage, as a salary that is subjected to Income Tax and National Insurance contributions (NICs). The employees also receive a second element of their remuneration without deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of APLO SVCS Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 4 December 2025 | Celsius Services Limited | 15873131 | Currently named | |
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Address Celsius Services Limited: 50 Princes Street, Ipswich, England, IP1 1RJ / TUML: 78 York Street, London, W1H 1DP Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients as employees of Celsius Services Limited. TUML act in collaboration with Celsius Services Limited by engaging with employment intermediaries. TUML receive payments on behalf of work carried out by Celsius Services Limited’s employees. TUML then forward these payments to Celsius Services Limited, who ultimately operate the payroll for the arrangements. Celsius Services Limited declares a portion of the employees’ earnings through Pay As You Earn (PAYE) and deducts Income Tax and National Insurance contributions (NICs). This rate of pay is often at, or close to, National Minimum Wage (NMW) or National Living Wage (NLW). The balance of the employees’ earnings is paid without the deduction of Income Tax and NICs. This payment may be described as a ‘loan’, ‘advance’, or ‘discretionary profit-sharing bonus’.
Other information from HMRC
HMRC’s view is that the untaxed payments made by Celsius Services Limited to their employees should be subject to Income Tax and NICs. 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 Celsius Services Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. Local Authority workers, particularly social workers, have been identified as a sector targeted by Celsius Services Limited.
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| 4 December 2025 | Erudite Partners Ltd | 14045053 | Currently named | |
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Address Erudite Partners Ltd:, Blinkbox Business Complex, Western Road, Deal, Kent, CT14 6PJ / Collabera Ltd: Episkopi, Karpasias 7, 4620 Limassol, Cyprus Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients or agencies under a contract of employment with Erudite Partners Ltd. At the same time, the individuals enter an agreement with a Cypriot company, Collabera Ltd, where the individuals grant Collabera Ltd an option on an Annuity Agreement. The individuals receive payment for their services from Erudite Partners Ltd, of which only a small part is subjected to Income Tax and National Insurance contributions (NICs). The part of the payment made without the deduction of Income Tax and NICs, is alleged to represent a ‘Grantee payment’ to the individuals, in return for the grant of the option and is paid by Erudite Partners Ltd on behalf of Collabera Ltd. It is HMRC’s view that this untaxed element represents additional income for the services provided by the individuals and therefore the entire payment should be subject to Income Tax and NICs.
Other information from HMRC
HMRC advise employees of Erudite Partners Ltd to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted from their income.
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| 4 December 2025 | Future Payroll Ltd | 15194046 | Currently named | |
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Address Future Payroll Ltd: Linley House, Dickinson Street, Manchester, M1 4LF Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Future Payroll Ltd. Employees receive part of their Future Payroll Ltd 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 and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of Future Payroll Ltd to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. HMRC are aware that some umbrella companies operate more than one scheme, such as a standard compliant scheme and a non-compliant scheme. It appears employees within the social work sector are among those who have adopted the use of these arrangements. These individuals are likely to be employed through Future Payroll Ltd but are undertaking work for third parties such as local authorities.
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| 4 December 2025 | Glendyne Limited | 13686783 | Currently named | |
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Address Dept 4297, 43 Owston Road, Carcroft, Doncaster, DN6 8DA Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of GL. Employees receive part of their GL 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 GL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. It appears employees within the social work and healthcare sector have adopted the use of these arrangements. These individuals are likely to be employed through GL but are undertaking work for local authorities and within the healthcare sector.
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| 4 December 2025 | Link Requirements Limited | 15958318 | Currently named | |
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Address LRL: Suite 20b Unit 3, Q Estate, Melton Road, Queniborough, Leicester, LE7 3FP Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of LRL. Employees receive part of their LRL 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.
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| 4 December 2025 | Pennywise Contracts Limited | 15560053 | Currently named | |
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Address PCL: Suite 20b Unit3 Q Estate, Melton Road, Queniborough, Leicester, LE7 3FP Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of PCL. Some employees of PCL 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), which is subjected to deductions of Income Tax and National Insurance contributions (NICs). The employees also receive a secondary element of their remuneration that is made without the deduction of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the PCL employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of PCL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. PCL appears to target employees within the healthcare sector, NHS and Local authority workers for participation in the arrangements.
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| 13 November 2025 | Alpha Pay Limited | — | Currently named | |
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Address APL: 64a Athol Street Douglas, Isle of Man, IM1 1JE Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide their services to end clients as employees of APL. APL pay scheme users part of their remuneration as a salary that is subjected to Income Tax and National Insurance contributions (NICs). Scheme users also receive a secondary element of their remuneration without deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of APL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 13 November 2025 | Datamatics HR & Consultancy Ltd | 10546096 | Currently named | |
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Address Datamatics HR & Consultancy Ltd: Amba House, 15 College Road, Harrow, HA1 1BA / Datamatics UK Limited: Amba House, 15 College Road, Harrow, HA1 1BA Named under Finance Act 2022
How the scheme is claimed to work
Individuals sign contracts of employment with Datamatics HR & Consultancy Ltd or Datamatics UK Limited. In addition, they may also sign a contract of employment with an offshore company. Employees receive part of their remuneration paid to them by Datamatics HR & Consultancy Ltd 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). The balance of their remuneration is paid to them in one of 2 ways. It is either paid by Datamatics HR & Consultancy Ltd (sometimes described as a ‘Bonus’ on payslips), or as payment made through an offshore company. In either case, the additional payments are made without the deduction of UK Income Tax or NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to UK Income Tax and NICs. HMRC advise employees of Datamatics HR & Consultancy Limited and Datamatics UK Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. It appears that employees from a range of sectors have adopted the arrangements but particularly those employed within the healthcare and the IT sectors. Employees within the healthcare sector are likely to be employed through Datamatics HR & Consultancy or Datamatics UK Limited but undertake work for the NHS.
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| 13 November 2025 | IFL Management Limited | — | Currently named | |
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Address IFL Management Limited: Runnymede Malthouse Business Centre, Malthouse Lane, Egham, Surrey, TW20 9BD / Tarbet Ltd: The Willows, Stroude Road, Egham, TW20 9UW / Jupiter Online Limited: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF / Payroll (UK) Limited: The Willows, Stroude Road, Egham, TW20 9UW / Talmine Contracts Ltd: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF / Milton Contracts Ltd: The Willows, Stroude Road, Egham, TW20 9UW / Bocaddon Limited: The Willows Milton Park, Stroude Road, Egham, Surrey, TW20 9UW / Iceni Trading Ltd: The Willows, Stroude Road, Egham, TW20 9UW Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as self-employed contractors who utilise IFL Management Limited’s umbrella services. IFL Management Limited receives money from end clients or agencies. After IFL Management Limited deduct their fee, the funds are passed down to either Tarbet Ltd or Jupiter Online Ltd, or both of them, who then facilitate payments to one or more of, Tarbet Ltd, Payroll (UK) Limited, Talmine Contracts Ltd, Milton Contracts Ltd, Bocaddon Limited, or Iceni Trading Ltd (the ‘Payment Companies’). One of the Payment Companies’ part-pays the contractors for the work carried out. These payments are reported on the contractors’ self-assessment tax returns. The contractors then receive a second amount from one of the Payment Companies which is described as a ‘self-employed workers loan’. The second payment is not declared on the self-assessment return and neither Income Tax or National Insurance contributions is remitted to HMRC.
Other information from HMRC
HMRC’s view is that the second payment, described as a loan, is part of the remuneration for the services provided to the end client. The amounts should therefore be included as income in self-assessment tax returns. 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 self-employed contractors working via IFL Management Limited to familiarise themselves with guidance on income tax. As at the date of publishing, Mark Aylwin Turner has control or significant influence over all of the payment companies.
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| 13 November 2025 | Manthon Solutions Limited | 14641932 | Currently named | |
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Address 128 City Road, London EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Manthon Solutions Limited. Employees receive part of their Manthon Solutions Limited remuneration at a significantly reduced rate from their historical earnings with previous employers, which is subject to deduction of Income Tax and National Insurance contributions (NICs). Employees receive the balance of their remuneration without the deduction of Income Tax and NICs.
Other information from HMRC
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 Manthon Solutions Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted from their income.
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| 30 October 2025 | Temp Contracting Limited | 13680669 | Currently named | |
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Address TCL (Former address:) Suite 11 Shiftworks, Royal House, 14 Upper Northgate Street, Chester, CH1 4EE Named under Finance Act 2022
How the scheme is claimed to work
Scheme participants provide their services to end clients as employees of TCL. TCL pay scheme participants part of their remuneration as a salary that is subjected to Income Tax and National Insurance contributions (NICs). Scheme participants also receive a secondary element of their remuneration without deductions of Income Tax and NICs.
Other information from HMRC
The company provides their services via the website vividpay.co.uk. 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 TCL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. HMRC allocated a Scheme Reference Number, 69449871, to the arrangements on 5 August 2025 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes’. You can find out what this means for you by reading the DOTAS guidance.
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| 16 October 2025 | Echo Pay Limited | 15424591 | Currently named | |
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Address Suite 20b Unit3 Q Estate, Melton Road, Queniborough, Leicester, LE7 3FP Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Echo Pay Limited. Employees receive part of their Echo Pay Limited remuneration at a rate close to the National Minimum Wage or National Living Wage which is subject to Income Tax and National Insurance contributions (NICs). Employees receive the balance of their remuneration without the deduction of Income Tax or NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of Echo Pay Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted from their income.
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| 16 October 2025 | T.U Paye Limited | SC840041 | Currently named | |
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Address T.U Paye Limited: 272 Bath Street, Glasgow, Scotland, G2 4JR Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide services to end clients as employees of T.U Paye Limited. Employees receive part of their T.U Paye Limited 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 and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC has reason to suspect that T.U Paye Limited users are working in local councils and the NHS. 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 T.U Paye Limited to familiarise themselves with the Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 9 October 2025 | Contractor Expert Ltd | — | Currently named | |
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Address Office 17, Innovation House, Innovation Way, Discovery Park, Sandwich, Kent, CT13 9FF Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of CEL. 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.
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| 9 October 2025 | Progress Payroll Limited | 15560543 | Currently named | |
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Address Suite 20b, Unit 3, Q Estate, Melton Road, Queniborough, Leicester, LE7 3FP Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Progress Payroll Limited. Some employees of Progress Payroll 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 (NMW), that is subject to deductions for Income Tax and National Insurance contributions (NICs). The employees also receive a secondary element of their remuneration that is paid without the deduction of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the Progress Payroll Limited employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of Progress Payroll Limited to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. Progress Payroll Limited appears to target employees within the healthcare sector and NHS workers for participation in the arrangements.
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| 25 September 2025 | Endeavour Services Ltd | 16080455 | Currently named | |
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Address 128 City Road, London, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Endeavour Services Ltd. All employees of Endeavour Services 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). We suspect that the employees also receive a secondary element of their remuneration without deductions for Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC has reason to suspect that Endeavour Services Ltd users are working in local councils. 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 Endeavour Services Ltd to familiarise themselves with the Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 18 September 2025 | Complete Payment Solutions Limited | 15593132 | Currently named | |
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Address Complete Payment Solutions Limited: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as employees of Complete Payment Solutions Limited (CPSL). Some employees of CPSL receive part of their remuneration, paid at or close to the rate of National Minimum Wage, as a salary that is subjected to Income Tax and National Insurance contributions (NICs). The employees also receive a second element of their remuneration without deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of CPSL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 18 September 2025 | GCWealth RT Limited | 07478214 | Currently named | |
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Address GCWRTL: Previous Registered Office: International House, 36-38 Cornhill, London, EC3V 3NG / GCWAL: C/O Belize Offshore Services Limited, Suite 5 Garden City Plaza, Mountainview Boulevard, Belmopen, BELIZE Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
A scheme user (usually a company) contributes to an offshore trust (described as a ‘Creditor Protection Trust’) and claims the contribution as a deductible Corporation Tax expense. The money claimed to have been contributed to the trust is subsequently transferred, typically via another company, to the scheme user’s director (or used as instructed by the director). The director claims the funds received this way are held by them as ‘loans’ or in a fiduciary capacity.
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| 14 August 2025 | AIT Umbrella Limited | 10943923 | Currently named | |
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Address Bromsgrove Enterprise Park, Isidore Road, Bromsgrove, Worcestershire, B60 3ET Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of AIT. Employees receive part of their AIT 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 and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of AIT to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. It appears employees within the social work sector have adopted the use of these arrangements. These individuals are likely to be employed through AIT but are undertaking work for local authorities and within the healthcare sector.
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| 14 August 2025 | Pay APL Limited | 15860821 | Currently named | |
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Address Pay APL Limited: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of PAL. Employees receive part of their PAL remuneration at a rate close to the National Minimum Wage or National Living Wage which is subject to Income Tax and National Insurance contributions (NICs). Employees receive the balance of their PAL remuneration without the deductions of Income Tax or NICs.
Other information from HMRC
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 PAL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 14 August 2025 | Real Payments Limited | 15426462 | Currently named | |
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Address RPL: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of RPL. Employees receive part of their RPL 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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| 14 August 2025 | Regis Limited | — | Currently named | |
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Address RL: Unit 15, Balderton Court, Balthane Industrial Estate, Ballasalla, Isle of Man, IM9 2AJ / EUL (in liquidation): Former address: International House, 61 Mosely Street, Manchester, M2 3HZ / IUL (in liquidation): Former address — Piccadilly Business Centre, Unit C Aldow Enterprise Park, Manchester, M12 6AE Named under Finance Act 2022
How the scheme is claimed to work
The scheme users sign a contract of employment and commercial loan agreement’ with RL, a company based in the Isle of Man. A UK umbrella company, either Ernest Umbrella Limited or Imagine Umbrella Limited then enter into an ‘Agreement for Administrative Services’ with RL. The UK umbrella company then contracts the scheme user’s services to a UK end client, sometimes via a UK intermediary/agency, who in turn pay for the scheme user’s services. The UK umbrella company pay the gross contracted value to RL. RL then pay a fee to the UK umbrella company. RL pay a salary at the minimum rate permitted under the National Minimum Wage Act 1998 to the scheme user with Income Tax and National Insurance contributions (NICs) deducted. RL also made a second payment to the scheme users, described as a loan, and made pursuant to the loan agreement, without deductions of Income Tax or NICs.
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| 31 July 2025 | Evolve Payroll Ltd | 15158959 | Currently named | |
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Address EPL: 4 Spur Road, Cosham, Portsmouth, United Kingdom, PO6 3EB Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of EPL. 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 deductions of Income Tax or NICs as it is claimed not to count as employment income.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of EPL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. Employees within the social work sector are among those who have adopted the use of these arrangements. These individuals are likely to be employed through EPL but are undertaking work for third parties such as local authorities.
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| 31 July 2025 | Fortunes Payroll Ltd | 14168552 | Currently named | |
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Address Fortunes Payroll Ltd, 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Fortunes Payroll 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 as it is claimed not to count as employment income.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC advise employees of Fortunes Payroll Ltd to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income. Employees within the social work sector are among those who have adopted the use of these arrangements. These individuals are likely to be employed through Fortunes Payroll Ltd but are undertaking work for third parties such as local authorities.
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| 31 July 2025 | Modus Umbrella Limited | 13011077 | Currently named | |
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Address Modus Umbrella Limited: 2 Falcon Gate, Welwyn Garden City, Hertford, Hertfordshire, AL7 1TW Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients as employees of Modus Umbrella Limited. The individuals receive payment for their services from Modus Umbrella Limited, and this is made up of 2 elements. 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 second element is paid without deductions for Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously published Spotlight 60 on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies. HMRC suspects the arrangement is targeted at NHS 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 Modus Umbrella Limited 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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| 31 July 2025 | T.U Pay Limited | SC806609 | Currently named | |
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Address 272 Bath Street, Glasgow, Scotland, G2 4JR Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide services to end clients as employees of TUPL. Employees receive part of their TUPL 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 and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously published Spotlight 60 on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies. HMRC has reason to suspect that TUPL users are working in local councils and the NHS. 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 TUPL 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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| 31 July 2025 | Umbrella Contracts Limited | SC192044 | Currently named | |
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Address UCL: former address — Kintail House, Beechwood Park, Inverness, Scotland, IV2 3BW / FASL: Crown House, 27 Old Gloucester Street, London, England, WC1N 3AX / MCSL: Victoria House, Victoria, Mahe, Seychelles Named under Finance Act 2022
How the scheme is claimed to work
Scheme user signs an employment contract with UCL. The UCL contract states that the user will be paid a salary equivalent to the National Minimum Wage (NMW). UCL provide the services of the scheme users to end clients, and invoice them for the provision of those services. In accordance with the employment contract, UCL pays the user a NMW salary with Income Tax and National Insurance contributions (NICs) deducted. On or around the same day the salary is paid, FASL make a larger payment to the scheme user, but without deductions of Income Tax and NICs.
Other information from HMRC
FASL claims that the monies paid to workers are ‘financier loans’ and they are acting upon instructions from Seychelles-registered company MCSL. HMRC’s view is that both payments should be treated as ‘normal income/as the user’s salary’, and 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 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 UCL 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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| 24 July 2025 | Knights Network Limited | — | Currently named | |
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Address KNL, (as of 14 November 2024) Dept 4972a 43 Owston Road, Carcroft, Doncaster DN6 8DA / Previous address: 196 High Road, London, England, N22 8HH Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of KNL. 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ payment should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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, for example, a standard compliant scheme and a non-compliant scheme. HMRC advise employees of KNL 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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| 24 July 2025 | Less Tax For Landlords Limited | — | Currently named | |
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Address LT4L, c/o OCGAL, Biz Hub Tees Valley, Belasis Hall Technology Park, Coxwold Way, Billingham, TS23 4EA / OCGAL, Biz Hub Tees Valley, Belasis Hall Technology Park, Coxwold Way, Billingham, TS23 4EA Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
The individual landlords, their family members, or both, (herein referred to as individual landlords) either set up a limited company or use a pre-existing company for the scheme. The individual landlords and their company set up a Limited Liability Partnership (LLP) and both become members of it. The individual landlords make a declaration of trust over the properties they hold in their property business in favour of the LLP. The members of the LLP allocate the LLP profits to themselves on a discretionary basis. Most or a large part of the business profits is allocated to the corporate member of the LLP.
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| 12 June 2025 | Head Restart Limited | 15432663 | Currently named | |
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Address HRL: Suite 2a Blackthorn House, St Pauls Square, Birmingham, B3 1RL Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of HRL. The remuneration for some employees of HRL is made up of 2 elements. The first element is a salary, paid at or close to the minimum rate permitted under the National Minimum Wage Act 1998, that is subject to deductions for Income Tax and National Insurance contributions (NICs). The second element is made without deductions for Income Tax and NICs.
Other information from HMRC
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 have previously published Spotlight 60 on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies. HRL appears to target 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 HRL 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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| 12 June 2025 | Signature Professional Limited | 15486244 | Currently named | |
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Address Signature Professional Limited: 50 Princes Street, Ipswich, Suffolk, England, IP1 1RJ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Signature Professional Limited. Employees receive part of their remuneration paid 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 of Signature Professional Limited receive the balance of their remuneration which is disguised as another form of payment without deductions for Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and 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. Signature Professional Limited appears to target those who work in the healthcare sector. 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 Signature Professional Limited 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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| 5 June 2025 | Arrow Tree Consulting Limited | 15424716 | Currently named | |
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Address 85 Great Portland Street, First Floor, London, England, W1W 7LT Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Arrow Tree Consulting 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 Arrow Tree Consulting Limited to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. HMRC has identified that some of the users of these arrangements are employed within the social work and healthcare sectors. These individuals are likely to be employed through Arrow Tree Consulting Limited but are undertaking work for local authorities.
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| 5 June 2025 | Pure Employment Limited | 14910155 | Currently named | |
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Address Pure Employment Limited: 128 City Road, London, United Kingdom, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of Pure Employment 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 of Income Tax and National Insurance contributions (NICs). Employees receive the balance of their remuneration without the deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 Pure Employment Limited to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. Employees within the social work sector are among those who have adopted the use of these arrangements. These individuals are likely to be employed through Pure Employment Limited but are undertaking work for third parties such as local authorities.
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| 29 May 2025 | GL Platinum Ltd | 13918832 | Currently named | |
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Address 7 Bell Yard, London, WC2A 2JR / 117 Ellingham Way, Ashford, TN23 6LZ Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients, via employment agencies where applicable, as employees of GL Platinum Ltd. GL Platinum Ltd declare a portion of the employees’ earnings through Pay As You Earn (PAYE) and deduct Income Tax and National Insurance contributions (NICs). The rate of pay is often at or close to the National Minimum Wage. The balance of the employees’ earnings, which may be described as ‘Retained Profit’ on the payslips issued by GL Platinum Ltd, is paid without the deduction of Income Tax and NICs. HMRC suspect that GL Premier Ltd have been a promoter in relation to the scheme and were originally responsible for the steps described above.
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| 29 May 2025 | The Brightest Future Limited | 14836170 | Currently named | |
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Address The Mclaren Building, 46, The Priory, Queensway, Birmingham, B4 7LR Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as employees of The Brightest Future Limited (TBFL). Some employees of TBFL receive part of their remuneration, paid at or close to the rate of the National Minimum Wage, as a salary that is subjected to deductions for Income Tax and National Insurance contributions (NICs). Those TBFL employees also receive a further element of their remuneration that is not subjected to deductions of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees pay are earnings from employment and 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 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 The Brightest Future Limited to familiarise themselves with the guidance and to satisfy themselves that the correct amounts of tax and NICs are being deducted from their income.
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| 22 May 2025 | Compas Limited | — | Currently named | |
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Address Compas Limited: Unit 15, Balderton Court, Balthane Industrial Estate, Ballasalla, Isle of Man, IM9 2AJ / Ernest Umbrella Limited: (in liquidation) former address — International House, 61 Mosely Street, Manchester, M2 3HZ / Imagine Umbrella Limited: Piccadilly Business Centre, Unit C Aldow Enterprise Park, Manchester, M12 6AE Named under Finance Act 2022
How the scheme is claimed to work
The scheme users sign a Contract of Employment and Commercial Loan Agreement with Compas Limited, a company based in the Isle of Man. A UK umbrella company, either Ernest Umbrella Limited or Imagine Umbrella Limited, then enters into an Agreement for Administrative Services with Compas Limited. Ernest Umbrella Limited/Imagine Umbrella Limited 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 Ernest Umbrella Limited/Imagine Umbrella Limited. Ernest Umbrella Limited/Imagine Umbrella Limited then invoice Compas Limited to obtain a fee for their services Ernest Umbrella Limited/Imagine Umbrella Limited then send the money for the scheme user’s services to Compas Limited. Compas Limited makes a single payment to the scheme users comprising a National Minimum Wage/National Living Wage salary with Income Tax and National Insurance contributions (NICs) deducted, and a payment, described as a loan, pursuant to the loan agreement, which is made without deductions of Income Tax or NICs.
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| 22 May 2025 | NM Recruitment Services Ltd | — | Currently named | |
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Address Liquidators address as of 27 March 2025: Antony Batty & Company LLP, 3 Field Court, Gray’s Inn, London, WC1R 5EF / Previously: Fifth Floor, Suite 23, 63-66 Hatton Garden, London, EC1N 8LE Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients as employees of NMRSL. The individuals receive payment for their services which is made up of two elements. 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 second element is paid without deductions of Income Tax and NICs.
Other information from HMRC
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 have previously 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 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 NMRSL 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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| 15 May 2025 | Minerva Services Ltd | — | Currently named | |
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Address PO Box 445, Suite 5 Garden City Plaza, Mountainview Boulevard, Belmopan, Belize |
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| 15 May 2025 | Paul Baxendale-Walker | — | Currently named | |
| 1 May 2025 | Back Office Systems 1 Limited | — | Currently named | |
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Address 7 Bell Yard, Bell Yard, London, England, WC2A 2JR Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve scheme users providing 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.
Other information from HMRC
HMRC’s view is that both elements of the employee’s pay are earnings from employment and therefore subject to Income Tax and NICs. 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, 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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| 10 April 2025 | Back Office Assistance 1 Limited | — | Currently named | |
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Address 167-169 Great Portland Street, London, W1W 5PF Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their 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.
Other information from HMRC
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 has previously published 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 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.
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| 10 April 2025 | Back Office Services 1 Limited | — | Currently named | |
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Address 167-169 Great Portland Street, London, W1W 5PF Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their 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.
Other information from HMRC
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 has previously published 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 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.
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| 3 April 2025 | Expertise Solutions Limited | — | Currently named | |
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Address Former address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as 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 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.
Other information from HMRC
HMRC’s view is that both elements of pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 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.
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| 3 April 2025 | K & B Umbrella Ltd | 14581885 | Currently named | |
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Address International House, 307 Cotton Exchange, Old Hall Street, Liverpool, United Kingdom, L3 9LQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 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.
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| 13 March 2025 | Payroll Professors Limited | 15492817 | Currently named | |
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Address 7 Bell Yard, London, WC2A 2JR Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
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 have previously published Spotlight 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.
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| 13 March 2025 | PRC Recruitment Ltd | 14106838 | Currently named | |
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Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay are employment income, and therefore subject to Income Tax and NICs. 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 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 correct amount of tax is being deducted on their income.
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| 13 March 2025 | Universe Payroll Limited | — | Currently named | |
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Address UPL: 7 Bell Yard, London, WC2A 2JR / Bonzai Umbrella Limited: 7 Bell Yard, London, WC2A 2JR Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve scheme users 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.
Other information from HMRC
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 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 UPL 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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| 27 February 2025 | Earneze Limited | — | Currently named | |
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Address Earneze Limited, 20-22 Wenlock Road, London, England, N1 7GU Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ payment should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 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 appears employees within the social work sector have adopted the use of these arrangements.
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| 27 February 2025 | Level Up Associates Limited | — | Currently named | |
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Address 7 Bell Yard, London, WC2A 2JR Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of LUA. Some employees of LUA receive their remuneration made up of two 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously 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.
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| 20 February 2025 | Imace Limited | — | Currently named | |
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Address 58 Office 565, 58 Peregrine Road, Hainault, Ilford, Essex, IG6 3SZ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously 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 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.
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| 13 February 2025 | Remuneration Assured Ltd | — | Currently named | |
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Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of RAL. Employees receive part of their RAL 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 RAL remuneration without the deduction of Income Tax or NICs.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay are employment income, and therefore subject to Income Tax and NICs. 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 RAL 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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| 13 February 2025 | Trident Umbrella Limited | — | Currently named | |
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Address Two Four Nine North, Lynnfield House, Church Street, Altrincham, England, WA14 4DZ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously 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 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.
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| 13 February 2025 | Umbrella Link Ltd | — | Currently named | |
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Address Lonsdale Gate, Lonsdale Gardens, Tunbridge Wells, TN1 1NU Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously 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. Representatives of contractorteam.co.uk (CT), contact individuals, including some they have identified on social media websites. Often this includes emailing individuals using the following email address format: support(number)@contractorteam.co.uk. CT provide pay illustrations with their emails, offering potential employees the opportunity to maximise take-home pay. They make referrals to umbrella companies promoting tax avoidance schemes and request personal data to pass on to those umbrella companies.
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| 13 February 2025 | Vortexx Limited | 15191526 | Currently named | |
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Address Office One, 1 Coldbath Square, London, England, EC1R 5HL Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ payment should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 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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| 6 February 2025 | Vision Human Resource Solutions Ltd | — | Currently named | |
| 30 January 2025 | Medbridge Ltd | — | Currently named | |
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Address Former address: Suite 2a, Blackthorn House, St Pauls Square, Birmingham, B3 1RL Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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 element of their remuneration which is made without deduction of Income Tax and NICs.
Other information from HMRC
HMRC’s view is that both elements of pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously published Spotlight 60 on 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.
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| 23 January 2025 | Pinnacle and Partners Limited | — | Currently named | |
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Address Pinnacle and Partners Limited: 27 Old Gloucester Street, London, WC1N 3AX / OCP: Unit 2 Close Beg, Peel, Isle of Man IM5 1XF Named under Finance Act 2022
How the scheme is claimed to work
Some employees of Pinnacle and Partners Limited 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 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.
Other information from HMRC
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 have previously published Spotlight 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.
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| 16 January 2025 | Calculate Limited | — | Currently named | |
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Address Dept 3671, 601 International House, 223 Regent Street, London, W1B 2QD Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as 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.
Other information from HMRC
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 has previously published 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.
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| 16 January 2025 | Masterstroke Solutions Limited | — | Currently named | |
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Address 128 City Road, London, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously 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.
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| 16 January 2025 | Penhale Solutions Limited | — | Currently named | |
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Address Former address: 71-75 Shelton Street, London, WC2H 9JQ / Current Address (as of 25 September 2024): 128 City Road, London, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of PSL. PSL employees receive part of their remuneration at a rate close to the National Minimum Wage or National Living Wage which is subject to Income Tax and National Insurance contributions (NICs). Employees receive the balance of their remuneration without the deduction of Income Tax or NICs.
Other information from HMRC
HMRC’s view is that both elements of the PSL employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 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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| 16 January 2025 | Rainwize Umbrella Limited | — | Currently named | |
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Address 307 Cotton Exchange Building, Old Hall Street, Liverpool, L3 9LQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. HMRC have previously 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.
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| 16 January 2025 | Stark Payment Services Ltd | — | Currently named | |
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Address Former address: Unity Building, 20 Chapel Street, Liverpool, L3 9AG Named under Finance Act 2022
How the scheme is claimed to work
Some employees of SPSL 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 subjected to the deduction of Income Tax and NICs.
Other information from HMRC
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 have previously published Spotlight 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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| 5 December 2024 | Acquda Solutions Limited | — | Currently named | |
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Address 50 Princes Street, Ipswich, IP1 1RJ Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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.
Other information from HMRC
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 have previously 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 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.
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| 5 December 2024 | First Paye Consultants Limited | — | Currently named | |
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Address Former address: 20 Chapel Street, Liverpool, L3 9AG Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of FPCL. Employees receive part of 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.
Other information from HMRC
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 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 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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| 28 November 2024 | Astra Limited | — | Currently named | |
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Address Astra Limited: 6th Floor, Harbour Court, Lord Street, Douglas, Isle of Man, IM1 4LN / TGI Payday Limited: 145 Grimsby Road, Cleethorpes, England, DN35 7DG Named under Finance Act 2022
How the scheme is claimed to work
The scheme users sign a contract of employment 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.
Other information from HMRC
HMRC also issued a POTAS Stop Notice to Astra Limited and TGI Payday Limited on 16 July 2024 and published details of the arrangements on 14 November 2024. The Stop Notice requires Astra 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.
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| 28 November 2024 | Clear Water Administration Limited | — | Currently named | |
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Address Level One Basecamp, Liverpool, 49 Jamaica Street, Liverpool, L1 0AH Named under Finance Act 2022
How the scheme is claimed to work
Employees of CWA receive part of their 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.
Other information from HMRC
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 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 CWA 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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| 28 November 2024 | Greenlight Payroll Services Limited | — | Currently named | |
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Address Greenlight Payroll Services Limited, 128 City Road, London, EC1V 2NX / Greenlight Payroll Operations Ltd (in liquidation), Wolverhampton Science Park, Wolverhampton, WV10 9TG / Dynasty Payroll Solutions Ltd, International House, Admirals Way, London, E14 9XL Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their 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 of the arrangements and HMRC suspect it has a role in relation to making the arrangements available for implementation.
Other information from HMRC
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 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.
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| 28 November 2024 | Titan Payment Solutions Limited | — | Currently named | |
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Address 196 High Road, Wood Green, London, N22 8HH Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
It is HMRC’s view that both elements of the pay made to employees of TPS should be 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 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 themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 21 November 2024 | Intu Solutions Limited | — | Currently named | |
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Address 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals (scheme users) provide their services to end clients as employees of ISL. ISL then makes a single payment to the scheme users for their 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.
Other information from HMRC
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 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. 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.
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| 21 November 2024 | Jigsaw Payment Solutions Limited | — | Currently named | |
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Address 2a Connaught Avenue, London, E4 7AA Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their 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.
Other information from HMRC
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 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 JPSL 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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| 21 November 2024 | Protean Ltd | — | Currently named | |
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Address 128 City Road, London, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide services to end clients as 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.
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| 7 November 2024 | Adapt Limited | — | Currently named | |
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Address Adapt Limited, 6th Floor, Harbour Court, Lord Street, Douglas, Isle of Man, IM1 4LN / Frank Umbrella Limited, C/O Cg & Co, 27 Byrom Street, Manchester, M3 4PF / TGI Payday Limited, 145 Grimsby Road, Cleethorpes, England, DN35 7DG Named under Finance Act 2022
How the scheme is claimed to work
The scheme users sign a contract of employment 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.
Other information from HMRC
HMRC also issued a POTAS Stop Notice to Adapt Limited and TGI Payday Limited on 2 May 2024 and published details of the arrangements on 12 September 2024. The Stop Notice requires Adapt 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.
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| 7 November 2024 | Balance Bay Services Limited | 13323674 | Currently named | |
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Address BBSL: 7 Bell Yard, London, WC2A 2JR / MPL: Former address — 61 Bridge Street, Kington, HR5 3DJ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 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 themselves that the correct amount of tax is being deducted on their income. HMRC suspects that MPL has a role in the arrangements promoted by BBSL by sourcing and introducing users to BBSL.
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| 7 November 2024 | Century Umbrella Limited | — | Currently named | |
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Address Third Floor, 207 Regent Street, London, W1B 3HH Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the scheme users’ pay are employment income, and therefore subject to Income Tax and NICs. 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, 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.
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| 7 November 2024 | Consortius Solutions Limited | — | Currently named | |
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Address 128 City Road, London, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as employees of CSL. Employees receive part of their 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 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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| 7 November 2024 | Employe Limited | 15001745 | Currently named | |
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Address EL: (Former address) 50 Princess Street, Ipswich, IP1 1RJ / MPL: (Former address) 61 Bridge Street, Kington, HR5 3DJ Named under Finance Act 2022
How the scheme is claimed to work
Some employees of EL 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 Income Tax and National Insurance contributions (NICs). They also receive a secondary element of their remuneration without deductions for Income Tax and NICs.
Other information from HMRC
It is HMRC’s view is that both elements of the payments made to employees of EL should be subject to Income Tax and NICs. 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. 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. HMRC suspects that MPL has a role in the arrangements promoted by EL by sourcing and introducing users to EL.
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| 17 October 2024 | LWI Services Limited | — | Currently named | |
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Address Rodus Building 4th Floor, Road Reef PO Box 765, Road Town, Tortola, British Virgin Islands |
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| 10 October 2024 | Employe US Limited | 15349265 | Currently named | |
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Address EUL: (Former address) 7 Bell Yard, London, WC2A 2JR / MPL: (Former address) 61 Bridge Street, Kington, HR5 3DJ Named under Finance Act 2022
How the scheme is claimed to work
Employees of EUL 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). EUL employees also receive a secondary element of their remuneration that is not subjected to the deduction of Income Tax and NICs.
Other information from HMRC
It is HMRC’s view is that both elements of the pay made to employees of EUL should be subject to Income Tax and NICs. HMRC have previously published Spotlight 60 on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies. EUL appeared to target local authority and 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 EUL 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 MPL has a role in the arrangements promoted by EUL by sourcing and introducing users to EUL.
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| 10 October 2024 | Signature Pay Limited | — | Currently named | |
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Address Peter House, Oxford Street, Manchester, M1 5AN Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore should be subjected to Income Tax and NICs. 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 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.
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| 10 October 2024 | Umbrella Union Ltd | — | Currently named | |
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Address 9 Burns Street, Bootle L20 4RJ Named under Finance Act 2022
How the scheme is claimed to work
Employees of UUL 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). UUL Employees also receive a secondary element of their remuneration that is not subjected to the deduction of Income Tax and NICs.
Other information from HMRC
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 tax and NICs. 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 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.
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| 3 October 2024 | GL Premium Ltd | — | Currently named | |
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Address 7 Bell Yard, London, WC2A 2JR Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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.
Other information from HMRC
It is HMRC’s view that the ‘Retained Profit’ payments made by GLPL 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 GLPL 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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| 3 October 2024 | Just Standard Limited | — | Currently named | |
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Address 71-75, Shelton Street, London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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, 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.
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| 3 October 2024 | Miwsa Management Ltd | — | Currently named | |
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Address 7 Bell Yard, London, WC2A 2JR Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve scheme users providing 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.
Other information from HMRC
HMRC’s view is that both elements of pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 MML 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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| 26 September 2024 | Connection Point Ltd | — | Currently named | |
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Address Dept 4408, 196 High Road, London, N22 8HH Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to tax and NICs. 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 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.
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| 26 September 2024 | Infrapro Consulting Limited | — | Removed by HMRC 4 September 2025 | |
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Address 4 Admiral Way, Doxford International Business Park, Sunderland, United Kingdom, SR3 3XW Named under Finance Act 2022
How the scheme is claimed to work
Scheme users sign a contract of employment with 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.
Other information from HMRC
HMRC have previously published Spotlight 60 guidance on agency workers 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 ICL 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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| 26 September 2024 | Infrapro Consulting Ltd | — | Currently named | |
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Address 4 Admiral Way, Doxford International Business Park, Sunderland, United Kingdom, SR3 3XW Named under Finance Act 2022
How the scheme is claimed to work
Scheme users sign a contract of employment with 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.
Other information from HMRC
HMRC allocated a Scheme Reference Number, 04584462, to the arrangements on 20 March 2025 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes.’ You can find out what this means for you by reading the DOTAS guidance. HMRC has previously published Spotlight 60 guidance on agency workers 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 ICL 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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| 19 September 2024 | Burnsall Pay Ltd | — | Currently named | |
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Address 26 Bromwich House, 45 Howson Terrace, Richmond Hill, Richmond, TW10 6RU Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore subject to Income Tax and NICs. 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 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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| 19 September 2024 | Langan Scott and Co Ltd | — | Currently named | |
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Address 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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. 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.
Other information from HMRC
The SRN 09322856 was allocated to the arrangements on 5 September 2024. It is HMRC’s view that the ‘Retained Profit’ payments 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.
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| 19 September 2024 | Miwsa Limited | 14671026 | Currently named | |
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Address Miwsa Limited: Suite 03, 5 Wandsworth Road, Perivale, London, UB6 7JD / BHD: 28 Newcombe Court, Burgess Springs, Chelmsford, Essex, CM1 1QN / HRG: 30 Jameston, Bracknell, RG12 7WZ / HWX: 14 Ravensbury Avenue, Morden, SM4 6ET / JBL: 14 Ravensbury Avenue, Morden, SM4 6ET / JJDM: 20-22 Wenlock Road, London, N1 7GU / MPL: (Former address) 61 Bridge Street, Kington, HR5 3DJ Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their 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.
Other information from HMRC
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 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, 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, and JJDM have a role in relation to making available the scheme promoted by Miwsa Limited by acting as marketing and sales agents for Miwsa Limited and by introducing workers to Miwsa Limited 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. HMRC suspects MPL has a role in the arrangements promoted by Miwsa Limited by sourcing and introducing users to Miwsa Limited.
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| 19 September 2024 | Miwsa Ltd | — | Removed by HMRC between April 2025 and May 2025 | |
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Address Suite 03, 5 Wandsworth Road, Perivale, London, UB6 7JD Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their services to end clients as employees of Miwsa Ltd. 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.
Other information from HMRC
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 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, for example, a standard compliant scheme and a non-compliant scheme. HMRC advise employees of Miwsa Ltd 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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| 19 September 2024 | Property118 Ltd | — | Removed by HMRC 4 September 2025 | |
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Address P118: 1st Floor Woburn House, 84 St. Benedicts Street, Norwich, Norfolk, NR2 4AB / CBL: D5 Cotswold Airport, Kemble, Gloucestershire, England, GL7 6BA / P118: 1st Floor Woburn House, 84 St. Benedicts Street, Norwich, Norfolk, NR2 4AB / CBL: D5 Cotswold Airport, Kemble, Gloucestershire, England, GL7 6BA / SIPL: 2nd Floor (Rear Suite), 54-56 Victoria Street, St Albans, AL1 3HZ Named under Disclosure of Tax Avoidance Schemes (DOTAS) / Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Users enter into a ‘Sale and Purchase Agreement’ to 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 users, a company they manage, and a 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.
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| 19 September 2024 | United Pension Administration Ltd | — | Currently named | |
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Address United Pension Administration Ltd: 119060948-Companies House Default Address, Cardiff, CF14 8LH / Countryside Capital Ltd: Whitefriars Business Centre, 2nd floor, Whitefriars Lewins Mead, Bristol, BS1 2NT Named under Finance Act 2022
How the scheme is claimed to work
An individual transfers funds from an existing 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.
Other information from HMRC
HMRC advises users of this and similar schemes that payments from pension funds as described above should be declared via the individuals’ Self Assessment returns.
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| 12 September 2024 | 1st Choice Umbrella Ltd | — | Currently named | |
| 12 September 2024 | Adapt Ltd | — | Removed by HMRC between October 2024 and November 2024 | |
| 12 September 2024 | AI Global Workforce Ltd | — | Currently named | |
| 5 September 2024 | Everest Contracting Limited | — | Currently named | |
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Address Blinkbox Business Complex, Western Road, Deal, Kent, CT14 6PJ Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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 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.
Other information from HMRC
The company changed address on 10 June 2024. Everest Contracting Limited was previously registered at the address: 39 Norfolk Road, Desford, Leicester, CT14 6PJ. HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies.
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| 5 September 2024 | Innovate Limited | — | Currently named | |
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Address Innovate Limited (in liquidation), Previous registered office: 6th Floor, Harbour Court, Lord Street, Douglas, Isle of Man, IM1 LN (Registered office from 5 November 2019 to 19 January 2024) / Frank 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) Named under Finance Act 2022
How the scheme is claimed to work
The scheme users sign a contract of employment 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 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.
Other information from HMRC
HMRC’s view is that these payments are actually no different to normal income, and tax and National Insurance contributions are payable. HMRC have previously published 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 IL 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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| 5 September 2024 | Odyssey Payroll Limited | — | Currently named | |
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Address 28 Baddow Road, Chelmsford, England, CM2 0DG Named under Finance Act 2022
How the scheme is claimed to work
Scheme users sign a contract of employment with 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.
Other information from HMRC
HMRC have previously published a Spotlight on agency workers and contractors employed by 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 scheme users 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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| 5 September 2024 | Optima Limited | — | Currently named | |
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Address Optima Limited (in liquidation), Previous registered office: 6th Floor, Harbour Court, Lord Street, Douglas, Isle of Man, IM1 LN) / Frank Umbrella Limited (in liquidation), Previous registered office: 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) Named under Finance Act 2022
How the scheme is claimed to work
The scheme users sign a contract of employment 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.
Other information from HMRC
HMRC’s view is that the untaxed payments are actually no different to normal income, and tax and National Insurance contributions are payable. HMRC have previously published 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 Optima 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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| 29 August 2024 | Pazepay Limited | — | Currently named | |
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Address 20 Colmore Circus, Queensway, Birmingham, B4 6AT Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees pay should be treated as ‘normal income/as the user’s salary’, and therefore should be subjected to Income Tax and NICs. 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 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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| 29 August 2024 | Summit LED Ltd | — | Currently named | |
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Address Level One, Basecamp Liverpool, 49 Jamaica Street, Liverpool, Merseyside, England, L1 OAH Named under Finance Act 2022
How the scheme is claimed to work
SLL trading as Adept Pay. SLL’s employees 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.
Other information from HMRC
HMRC’s position is that the whole payment is normal income, and Income Tax and NICs are payable on it. HMRC have previously published 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 SLL 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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| 22 August 2024 | Fast Payroll UK Ltd | — | Currently named | |
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Address 167-169 Great Portland Street, London, W1W 5PF Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their services to end clients as employees of FPUK. The 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.
Other information from HMRC
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. In most cases, the user’s salary is paid 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.
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| 22 August 2024 | Your Pay Ltd | — | Currently named | |
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Address 71-75 Shelton Street, London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their 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.
Other information from HMRC
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 have previously published Spotlights on disguised remuneration schemes involving umbrella companies Spotlight 45 Spotlight 60 based on similar arrangements.
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| 8 August 2024 | Acquda Limited | 13492671 | Currently named | |
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Address AL: 45-55 Commercial Street, London, E1 6BD / MPL: (Former address) 61 Bridge Street, Kington, HR5 3DJ Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their 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.
Other information from HMRC
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 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 AL 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 MPL has a role in the arrangements promoted by AL by sourcing and introducing users to AL.
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| 8 August 2024 | Balance Bay Limited | 14820111 | Currently named | |
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Address BBL: (Former address) Office 5272 321-323 High Road, Romford, RM6 6AX / MPL: (Former address) 61 Bridge Street, Kington, HR5 3DJ Named under Finance Act 2022
How the scheme is claimed to work
Employees of BBL 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, they also receive a secondary element of their remuneration without deductions for Income Tax and NICs.
Other information from HMRC
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 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, 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. HMRC suspects that MPL has a role in the arrangements promoted by BBL by sourcing and introducing
users to BBL.
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| 8 August 2024 | On the Box Pay Ltd | — | Currently named | |
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Address Blinkbox Business Complex, Western Road, Deal, Kent, CT14 6PJ Named under Finance Act 2022
How the scheme is claimed to work
Scheme user enters into a contract of employment 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.
Other information from HMRC
HMRC view is that the untaxed element is normal income, and Income Tax and NICs is therefore payable on the entire amount. HMRC have previously published a Spotlight on agency workers and contractors employed by umbrella companies Spotlight 60. Representatives of contractorteam.co.uk (CT), contact individuals, including some they have identified on social media websites. Often this includes emailing individuals using the following email address format: support(number)@contractorteam.co.uk. CT provide pay illustrations with their emails, offering potential employees the opportunity to maximise take-home pay. They make referrals to umbrella companies promoting tax avoidance schemes and request personal data to pass on to those umbrella companies.
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| 8 August 2024 | Rosewood WM IO Services Ltd | — | Currently named | |
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Address Rosewood WM IO Services Ltd (in liquidation), 3rd Floor 86-90 Paul Street, London, EC2A 4NE / Dynasty Payroll Solutions Ltd, International House, Admirals Way, London, E14 9XL Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing 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.
Other information from HMRC
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 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.
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| 8 August 2024 | RW Operations Ltd | — | Currently named | |
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Address 85 Great Portland Street, London, W1W 7LT Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide their services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of pay should be treated as normal income/as the user’s salary, and therefore subject to Income Tax and NICs. 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 RWO 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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| 8 August 2024 | Whitebridge Management Ltd | — | Currently named | |
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Address 71-75 Shelton Street, London, England, WC2H 9JQ Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC considers 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 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 WML 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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| 8 August 2024 | Your PAYE Limited | — | Currently named | |
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Address Former address: 167-169 Great Portland Street, London, W1W 5PF / Current address: Floor 2, 10 Wellington Place, Leeds, LS1 4AP Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
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 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, 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.
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| 25 July 2024 | Blizzard Pay Ltd | — | Currently named | |
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Address 20 Wenlock Road, London, N1 7GU Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC’s view is that both elements of the employees’ pay are employment income, and therefore subject to Income Tax and NICs. 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 BPL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. HMRC allocated a scheme reference number (SRN) 03131798 to the arrangements on 11 March 2025 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes.’ You can find out what this means for you by reading the DOTAS guidance.
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| 18 July 2024 | B2BTradecard Limited | — | Currently named | |
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Address 1. B2B: 5a Chorley Business and Technology Centre, Euxton Lane, Chorley, PR7 6TE / 2. HBOMS: Highdown House 11 Highdown Road, Sydenham, Leamington Spa, Warwickshire, CV31 1XT / 3. HBOL: Highdown House, 11 Highdown Road, Leamington Spa, Warwickshire, England, CV31 1XT / 4. SPMCL: 12 Mirage 33 Shore Road, Sandbanks, Poole, Dorset, England, BH13 7PJ / 5. OCL: Office 16, Devonshire House Aviary Court, Wade Road, Basingstoke, Hampshire, England, RG24 8PE / 6. AAL: Suite 7, Europa House, 11 Marsham Way, Gerrards Cross, England, SL9 8BQ / 7. HBC: Unit 8, Acorn Business Park, Woodseats Close, Sheffield, South Yorkshire, S8 0TB / 8. RL: Highdown House 11 Highdown Road, Sydenham, Leamington Spa, Warwickshire, CV31 1XT Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve companies buying ‘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. B2B uses other companies to attract and refer scheme users. B2B enter into ‘Introducer Agreements’ with persons who will introduce their clients to B2B’s representatives and the B2B proposal. As per their Introducer Agreement, the companies receive fees based on a fixed percentage of the amounts spent by their clients on the B2B arrangements.
Other information from HMRC
It is HMRC’s view that the redeemed ‘loyalty points’ are disguised remuneration and as such should be subject to deductions for Income Tax and NICs. Furthermore, it is also HMRC’s view that the advertising amounts paid by the companies to B2B are not allowable deductions for Corporation tax purposes. In some cases, the companies referring clients to B2B also act as agents or statutory auditors, or both, for their clients.
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| 18 July 2024 | B2BTradecard Ltd | — | Removed by HMRC between September 2025 and October 2025 | |
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Address 5a Chorley Business and Technology Centre, Euxton Lane, Chorley, PR7 6TE Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve companies buying ‘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.
Other information from HMRC
It is HMRC’s view that the redeemed ‘loyalty points’ are disguised remuneration and as such should be subject to deductions for Income Tax and NICs. Furthermore, it is also HMRC’s view that the advertising amounts paid by the companies to B2B are not allowable deductions for Corporation tax purposes.
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| 18 July 2024 | New Mill Resourcing Ltd | — | Currently named | |
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Address 85 Great Portland Street, London, England, W1W 7LT Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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.
Other information from HMRC
HMRC have previously published a Spotlight on agency workers and contractors employed by 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 scheme users 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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| 18 July 2024 | Umbrella Zone Limited | — | Currently named | |
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Address Gainsborough House, 59-60 Thames Street, Windsor, SL4 1TX Named under Finance Act 2022
How the scheme is claimed to work
The scheme users’ total remuneration for their [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.
Other information from HMRC
It is HMRC’s view that all remuneration paid to employees of UZL is employment income and therefore taxable. HMRC have previously published guidance for agency workers and contractors employed by umbrella companies Spotlight 60.
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| 6 June 2024 | 365 Umbrella Ltd | — | Currently named | |
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Address 7 Jardine House, Bessborough Road, Harrow, HA1 3EX Named under Finance Act 2022
How the scheme is claimed to work
The scheme users’ total remuneration for their 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.
Other information from HMRC
HMRC’s view is that both elements of the payment should be treated as ‘normal income / as the users’ salary’ and 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 3UL 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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| 6 June 2024 | Cube Umbrella Limited | — | Currently named | |
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Address Fern Hill Business Centre, Foerster Chambers, Todd Street, Bury, Greater Manchester, England, BL9 5BJ Named under Finance Act 2022
How the scheme is claimed to work
Scheme users sign a contract of employment with 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.
Other information from HMRC
HMRC have previously published Spotlight 60 guidance on agency workers 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 CUL 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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| 6 June 2024 | Mountain View Admin Limited | — | Currently named | |
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Address Mountain View Admin Limited, 71-75 Shelton Street, Covent Garden, London. WC2H 9JQ (registered office) / Mountain View Administration Limited, Gatcombe House, Copnor Road, Portsmouth, Hampshire, PO3 5EJ (registered office) Named under Finance Act 2022
How the scheme is claimed to work
The scheme users enter an employment contract 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.
Other information from HMRC
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 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 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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| 16 May 2024 | Goldfish Umbrella Limited | — | Currently named | |
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Address Kemp House, 152-160 City Road, London, EC1V 2NX Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Scheme users enter into a contract of employment with GUL, providing their services to end clients. 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.
Other information from HMRC
HMRC have previously published a Spotlight on agency workers and contractors employed by 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 GUL 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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| 16 May 2024 | Signature Vintage Limited | — | Currently named | |
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Address 71-75 Shelton Street, London, Greater London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Signature Vintage Limited (SVL) employees 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.
Other information from HMRC
HMRC’s position is that the payment described as an ‘Option Granted’ is normal income and should therefore be subject to Income Tax and NICs. HMRC have previously published 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.
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| 16 May 2024 | We Are Ava Limited | — | Currently named | |
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Address 61 Mosley Street, Manchester, M2 3HZ Named under Finance Act 2022
How the scheme is claimed to work
Hunter State Limited now trading as We Are Ava 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.
Other information from HMRC
HMRC do not accept these arrangements work as claimed, and Income Tax and NICs should be accounted for on the ‘Option’ or ‘additional’ payments. It is HMRC’s view that the 2-payment 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 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.
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| 9 May 2024 | Accent Umbrella Ltd | — | Currently named | |
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Address Unit 1-3 Salisbury Street, Widnes, WA8 6PJ / Previous address: 20-22 Wenlock Road, London N1 7GU Named under Finance Act 2022
How the scheme is claimed to work
Some employees of AUL receive their remuneration 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.
Other information from HMRC
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 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, 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.
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| 25 April 2024 | Solucionis Limited | — | Currently named | |
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Address Horton House, Exchange Flags, Liverpool, England, L2 3PF Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
The remuneration for the scheme users’ services 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
Other information from HMRC
HMRC’s view is that these payments are actually no different to normal income, and tax and National Insurance contributions are payable. 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.
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| 25 April 2024 | Solucionis Ltd | — | Removed by HMRC 19 September 2024 | |
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Address Horton House, Exchange Flags, Liverpool, England, L2 3PF Named under Finance Act 2022
How the scheme is claimed to work
The remuneration for the scheme users’ services is artificially separated into two 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
Other information from HMRC
HMRC’s view is that these payments are actually no different to normal income, and tax and National Insurance contributions are payable. 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.
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| 18 April 2024 | Prime Umbrella Services Limited | — | Currently named | |
| 11 April 2024 | Acacia Management Services Limited | — | Currently named | |
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Address 27 Byrom Street, Manchester, M3 4PF / Former address: Office 2.24 Edward Pavilion, Albert Dock, Liverpool, L3 4AF Named under Finance Act 2022
How the scheme is claimed to work
Scheme users enter into a contract of employment and an option grant agreement with AMS. AMS invoice recruitment agencies for the services 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.
Other information from HMRC
HMRC’s view is that the option grant payments are no different to normal income, and tax and NICs are payable. HMRC have previously published 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; 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.
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| 11 April 2024 | Alphasaint Ltd | — | Currently named | |
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Address 71-75 Shelton Street, London, England, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
The scheme users’ total remuneration for their 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.
Other information from HMRC
The scheme reference number (SRN) 93135363 was allocated to the arrangements on 16 May 2024. HMRC’s view is that both elements of the payment should be treated as ‘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.
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| 11 April 2024 | Ultra Employment Ltd | — | Currently named | |
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Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
The scheme users enter an employment contract 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 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.
Other information from HMRC
HMRC have previously published Spotlights on disguised remuneration schemes involving umbrella companies (Spotlight 45 and Spotlight 60) based on similar arrangements. 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 UEL 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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| 11 April 2024 | Worx 4U Limited | — | Removed by HMRC between March 2025 and March 2025 | |
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Address Izabella House, Regent Place, City Centre, Birmingham, B1 3NJ Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
A company enters into a contract (the ‘Master Contract’) with ‘ContractingWorks’, the trading name of Worx 4U Limited (W4U), to provide consultancy services. W4U signs an agreement with the individual director of the company to undertake the consultancy services to W4U. W4U pay the individuals a flat fee per day exclusive of VAT. On the last working day of each week, the individual submits an invoice to W4U for their services. The individual then signs an advance deed, described as the ‘Self Employed Advance Deed’. This provides an initial advance against their future earnings or bonus payments of no more than £5,000 and, from time to time, such further advance payments as the company think fit. It is claimed that ‘Any advance payments shall be repayable’, but HMRC hold no evidence that these advance payments have ever repaid. W4U make the ‘advance’ payments to the individual, but without deductions for Income Tax or National Insurance contributions.
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| 21 March 2024 | Agile Pay Ltd | — | Currently named | |
| 14 March 2024 | Contractor Bureau Limited | — | Currently named | |
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Address 16 Upper Woburn place, London, WC1H 0AF Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Scheme Users are employed by CBL and 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.
Other information from HMRC
It is HMRC’s view the salary and advances paid to employees of CBL should be subject to tax and NICs. HMRC have previously published Spotlight 60 guidance for agency workers and contractors employed by umbrella companies.
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| 29 February 2024 | Abchurch Ltd | — | Currently named | |
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Address 128 City Road, London, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
It is HMRC’s view that all remuneration paid to employees of Abchurch Ltd is taxable. HMRC has previously published 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, 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.
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| 29 February 2024 | Procorre LLP | — | Currently named | |
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Address Procorre LLP: 33 Ubi Avenue 3, #08-61, Singapore 408868, Republic of Singapore / Corre Holdings SA: Rue du Rhône 118 Genève, GENÈVE, 1204 Switzerland Named under Finance Act 2022
How the scheme is claimed to work
Scheme users and their personal service 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.
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| 29 February 2024 | React Administration Services Limited | — | Currently named | |
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Address 2 Brunel Way, Slough, SL1 1XL Named under Finance Act 2022
How the scheme is claimed to work
The scheme user enters an employment contract 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.
Other information from HMRC
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 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 RASL 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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| 1 February 2024 | Flex Payroll and Accounting Services Ltd | — | Currently named | |
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Address Flex Payroll and Accounting Services Ltd, Stapeley House, London Road, Stapeley, Nantwich, England, CW5 7JW Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Flex PAS enters into a contract of employment 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.
Other information from HMRC
HMRC has previously published Spotlight 60 about the tax avoidance used by some 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. 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.
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| 1 February 2024 | Paystone Services Limited | — | Currently named | |
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Address 48 West George Street, Clyde Offices, 2nd Floor, Glasgow, Scotland, G2 1BP Named under Finance Act 2022
How the scheme is claimed to work
PSL pay scheme users a salary, which is 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.
Other information from HMRC
The scheme is targeted predominantly at workers within health, tech and energy sectors. Those in health, include doctors, nurses, speech therapists and podiatrists. HMRC do not accept these 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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| 25 January 2024 | Purity Ltd | — | Currently named | |
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Address 85 Great Portland Street, London, W1W 7LT Named under Finance Act 2022
How the scheme is claimed to work
Purity Ltd (‘Purity’) employees provide their 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.
Other information from HMRC
HMRC’s position is that the untaxed payment described on bank statements as ‘Purity Adv’ is normal income, and Income Tax and NICs are payable on it. HMRC have previously published 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 and to satisfy themselves that the correct amount of tax is being deducted on their income.
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| 21 December 2023 | MLG Pay Limited | — | Currently named | |
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Address MLG: Suite 101, 89 High Street, Sidcup, DA14 6DW Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
The scheme user’s total remuneration for their 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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| 1 December 2023 | Griffith Anderson Limited | — | Removed by HMRC between November 2024 and November 2024 | |
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Address Griffith Anderson Limited: 7 Bell Yard, London, WC2A 2JR / Umbrella Contracts Limited: Kintail House, Beechwood Park, Inverness, IV2 3BW Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme user signs an employment contract with UCL. The UCL contract states the user will be paid a salary equivalent to the National Minimum Wage (NMW) along with any commission to be paid under the ‘Commission Plan’ referred to in Schedule 1 of the contract. UCL invoices the end client. The scheme user is later provided with a copy of the ‘remittance note’ that the agency/end client sent to UCL. This confirms the scheme user’s rate of pay and hours worked. In accordance with the employment contract, UCL pays the user a NMW salary with tax and National Insurance contributions (NICs) deducted. Griffith Anderson Limited also makes a payment, but this is made without deductions for tax or NICs.
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| 1 December 2023 | Rainbowpay Ltd | — | Currently named | |
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Address Rainbowpay Ltd, formerly of 40 Caversham Road, Reading, RG1 7EB, now of Blinkbox Business Complex, Western Road Deal Kent, CT14 6PJ / Flexen Ltd, Stratigou Timagia, formerly of 15 Linda Court, 3rd Floor 6051, Larnaca, Cyprus, now of Zakynthu 2, Flat / Office 1, 6018, Larnaca, Cyprus Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
The arrangements involve individuals providing 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.
Other information from HMRC
HMRC have now notified both Rainbowpay Ltd and Flexen Ltd that a scheme reference number 58772053 has been allocated to the arrangements. You can find out what this means for you by reading the Disclosure of Tax Avoidance Schemes (DOTAS) guidance. HMRC have previously published Spotlight 60 on agency workers and contractors employed by umbrella companies.
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| 17 November 2023 | Bluestar Financial Solutions Limited | — | Currently named | |
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Address Bluestar Financial Solutions Limited, 71-75 Shelton Street, London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
The scheme user enters an employment contract with Bluestar Financial Solutions Limited who 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.
Other information from HMRC
HMRC have previously published Spotlight 60 on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies.
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| 17 November 2023 | Excala Solutions Limited | — | Currently named | |
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Address Excala Solutions Limited, 71-75 Shelton Street, Greater London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
The scheme user enters an employment contract 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 element is described as a ‘propelled payment’ with no tax and NICs deducted.
Other information from HMRC
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 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, 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.
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| 10 November 2023 | Hive Umbrella Ltd | — | Currently named | |
| 25 September 2023 | Edge Umbrella Limited | — | Currently named | |
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Address Edge Umbrella Limited, 78 York Street, London, W1H 1DP / Deposlo Holdings Ltd, 15 Linda Court, Floor 3, 6051, Lanaka, Cyprus Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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.
Other information from HMRC
HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies. Together with HMRC, The Committee of Advertising Practice (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.
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| 25 September 2023 | Hamilton Bradbury Ltd | — | Currently named | |
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Address Hamilton Bradbury Ltd, Pacific House, Relay Point, Wilnecote, Tamworth, Staffordshire, B77 5PA Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users sign a contract of employment and Loan Agreement with a company based in the Isle of 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.
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| 25 September 2023 | Olympus Contracting Limited | — | Currently named | |
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Address Olympus Contracting Limited, 63-66 Hatton Garden, London, EC1N 8LE Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
The arrangements involve users providing their 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.
Other information from HMRC
HMRC have previously published Spotlight 45 and Spotlight 60 guidance on disguised remuneration schemes involving umbrella companies based on similar arrangements.
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| 31 August 2023 | Pay Rec Limited | — | Currently named | |
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Address 1 Piccadilly Business Centre, Aldow Enterprise Park, Manchester, United Kingdom, M12 6AE Named under Finance Act 2022
How the scheme is claimed to work
Scheme users enter into an employment 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.
Other information from HMRC
It is HMRC’s view that the ‘advances’, paid against future bonus payments, are no different to normal income, and are therefore taxable. 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.
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| 31 August 2023 | Prime Umbrella Services Ltd | — | Currently named | |
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Address Prime Umbrella Services Ltd, 128 City Road, London, United Kingdom, EC1V 2NX Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Arrangements involve a user providing their 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.
Other information from HMRC
HMRC have allocated scheme reference number 79390150 to these arrangements. You can find out what this means for you by 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.
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| 24 August 2023 | Payeworx Ltd | — | Currently named | |
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Address Payeworx Ltd, Newspaper House, Tannery Lane, Penketh, Warrington, Cheshire, WA5 2UD / Contractor Buddy PCC Limited, 2nd Floor, Murdoch Chambers, South Quay, Douglas, Isle of Man, IM1 5AS Named under Finance Act 2022
How the scheme is claimed to work
The scheme user enters into an employment 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. However, the rate of Corporation Tax in the IOM is 0%. The scheme users are expected to distribute the alleged dividend amount as they see fit.
Other information from HMRC
HMRC have previously published Spotlight 60 guidance on disguised remuneration schemes.
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| 24 August 2023 | SmartPay Limited | — | Currently named | |
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Address SmartPay Limited, 3A Samuel Harris House, 5-11 St Georges Street, Douglas, Isle of Man, IM1 1AJ / SmartPay Limited, Blackpool Technology Management Centre, Faraday Way, Blackpool, Lancashire, FY2 0JW Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
SmartPay (IOM) signs an employment agreement with the scheme user and a contract for services 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.
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| 18 August 2023 | Dalespay Ltd | — | Currently named | |
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Address Dalespay Ltd: 17 Olav Road, Richmond, England, DL10 4PU / Bestia Holdings Ltd: 5-7 G&S Court, 4th Floor, Flat/Office 401 6030, Larnaca, Cyprus Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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.
Other information from HMRC
HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies.
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| 9 August 2023 | ABC Umbrella Ltd | — | Currently named | |
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Address ABC Umbrella Ltd: 1921 Building C/O Aspirations Accountancy, East Malling Business Centre, New Road, East Malling, United Kingdom, ME19 6BJ / Krevit Ltd: Stratigou Timagia, 15, Linda Court, Floor 3, 6051, Larnaca, Cyprus Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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 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.
Other information from HMRC
HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies. HMRC has now allocated a scheme reference number (SRN) 60705829 to the arrangements on 26 July 2023 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes’. Representatives of contractorteam.co.uk (CT), contact individuals, including some they have identified on social media websites. Often this includes emailing individuals using the following email address format: support(number)@contractorteam.co.uk. CT provide pay illustrations with their emails, offering potential employees the opportunity to maximise take-home pay. They make referrals to umbrella companies promoting tax avoidance schemes and request personal data to pass on to those umbrella companies.
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| 9 August 2023 | IP Global Consulting Ltd | — | Currently named | |
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Address Registered office: 63-66 Hatton Garden, London, EC1N 8LE / Trading address: 54 St. James Street, Liverpool, L1 0AB Named under Finance Act 2022
How the scheme is claimed to work
IPG invoices a recruitment agency for the services provided by a scheme user. On receipt 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.
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| 2 August 2023 | Apricot Umbrella Limited | — | Currently named | |
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Address Apricot Umbrella Limited: 20 North Lane, Canterbury, CT2 7PG / ADYE Ltd: 5-7 G&S Court, 4th Floor, Flat/Office 401, 6030, Larnaca, Cyprus Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing 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 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.
Other information from HMRC
HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies. HMRC has now allocated a scheme reference number (SRN) 49908130 to the arrangements on 02 November 2023 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes’.
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| 2 August 2023 | Countrywide Partners Limited | — | Currently named | |
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Address Suite 114, 25 Goodlass Road, Liverpool L24 9HJ Named under Finance Act 2022
How the scheme is claimed to work
Scheme users enter into employment contracts 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.
Other information from HMRC
HMRC previously allocated a scheme reference number (SRN) to the arrangements and notified CPL of this. SRN 20980718 was 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’.
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| 27 July 2023 | Easyway Umbrella Limited | — | Currently named | |
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Address Innovation House, 39 Mark Road, Hemel Hempstead Industrial Estate, Hemel Hempstead, HP2 7DN Named under Finance Act 2022
How the scheme is claimed to work
Individuals provide services to end clients as 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.
Other information from HMRC
HMRC considers the untaxed payments as normal income, and tax and National Insurance contributions are payable. 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, eg a standard compliant scheme and a non-compliant scheme. HMRC advise employees of Easyway Umbrella Limited 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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| 5 July 2023 | Veqta Ltd | — | Currently named | |
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Address Veqta Ltd (Malta), 1, Floor 2, Falzun Street, C/W Naxxar Road, Birkirkara, BKR1441, Malta / Veqta Ltd (UK), 20-22 Wenlock Road, London, N1 7GU Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide services to end clients through Veqta Ltd (a Maltese company) and its 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.
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| 5 July 2023 | Vision HR Solutions Ltd | — | Currently named | |
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Address Vision HR Solutions Ltd (Malta), 1, Floor 2, Falzun Street, C/W Naxxar Road, Birkirkara, BKR1441, Malta / Vision Human Resource Solutions Ltd, 71-75 Shelton Street, London, Greater London, WC2H 9JQ Named under Finance Act 2022
How the scheme is claimed to work
Scheme users provide services to end clients through Vision HR Solutions Ltd (a Maltese 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.
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| 28 June 2023 | Bluemoore Associates Ltd | — | Currently named | |
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Address Bluemoore Associates Ltd: 50 Princes Street, Ipswich, IP1 1RJ Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their 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.
Other information from HMRC
HMRC have previously published Spotlight 45 and Spotlight 60 guidance on disguised remuneration schemes involving umbrella companies based on similar arrangements. HMRC allocated a scheme reference number (SRN) 69178522 to the arrangements on 12 July 2023 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes.’
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| 28 June 2023 | Compliant Pay Ltd | — | Currently named | |
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Address Ultimate Planning Ltd: 128 City Road, London, EC1V 2NX Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve a scheme user 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.
Other information from HMRC
Compliant Pay Ltd went into liquidation on 25 April 2023. Their trading address prior to entering liquidation was: 128 City Road, 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.
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| 28 June 2023 | PAYE Services Limited | — | Currently named | |
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Address PAYE Services Limited, 7 Bell Yard, London, WC2A 2JR Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Arrangements involve users signing a ‘Contract for Employment’ with PAYE Services Limited (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.
Other information from HMRC
PSL sells its services via the website PAYE.com. PSL claims that it commits to provide further benefits to its employees, and that it is obliged to 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.
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| 28 June 2023 | Resource Hubco Limited | — | Currently named | |
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Address 3 Piccadilly Place, Manchester, M1 3BN Named under Finance Act 2022
How the scheme is claimed to work
The scheme user enters an employment contract with RHL who make composite payments to the 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.
Other information from HMRC
HMRC’s view is that these payments are actually no different to normal income, and tax and National Insurance contributions are payable. HMRC have previously published 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.
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| 11 May 2023 | Collect Consulting Limited | — | Removed by HMRC between April 2024 and May 2024 | |
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Address Collect Consulting Limited, C/O CKM Consultants Ltd, 1st Floor, Queen Victoria House, 41-43 Victoria Street, Douglas, Isle of Man, IM1 2LF / Select Umbrella Ltd, C/O CG & CO, Greg’s Building, 1 Booth Street, Manchester, M2 4DU Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users sign a contract of employment and loan agreement with Collect (IOM). Collect (IOM) then enters into a contract with Select (UK), a UK umbrella company, for the provision of the scheme user’s services. Select (UK) 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 Select (UK). Following the deduction of a fee, Select (UK) pay the remaining amount to Collect (IOM). Collect (IOM) pays a National Minimum 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.
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| 11 May 2023 | Connections Limited | — | Removed by HMRC between April 2024 and May 2024 | |
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Address Connections Limited, Unit 15E Tromode Estate, Carrs Lane, Douglas, Isle of Man, IM4 4RG / Bilberry Resourcing Ltd, Kingsgate, 62 High Street, Redhill, Surrey, RH1 1SG / 1st Choice Umbrella Ltd, Tamworth Enterprise Centre, Corporation Street, Tamworth, B79 7DN Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Connections (IOM) signs a Contract of Employment and Loan Agreement with the scheme users. Connections (IOM) enters into a contract with a UK Umbrella Company (either 1st Choice (UK) or Bilberry (UK)) for the provision of the scheme user’s services. The UK Umbrella Company then contracts the scheme user’s services to a UK intermediary/agency. The UK intermediary/agency then contracts the scheme users’ 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 Company. Following the deduction of a fee, the UK Umbrella Company pay the remaining amount to Connections (IOM). Connections (IOM) pays a salary to the scheme user at the applicable rate of the national minimum wage (or national living wage) and makes a separate payment described as a loan, which is made without deductions of income tax or National Insurance contributions.
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| 11 May 2023 | First Step Consulting Limited | — | Removed by HMRC between April 2024 and May 2024 | |
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Address First Step Consulting Limited, C/O CKM Consultants Ltd, 1st Floor Queen Victoria House, 41-43 Victoria Street, Douglas, Isle of Man, IM1 2LF / Simply Umbrella Services Limited, C/O Begbies Traynor (Central) LLP, Suite 9 River Court, 5 West Victoria Dock Road, Dundee, DD1 3JT Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users sign a contract of employment and loan agreement with First Step (IOM). First Step (IOM) then enters into a contract with Simply (UK), a UK umbrella company for the provision of the scheme user’s services. Simply (UK) 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 Simply (UK). Following the deduction of a fee, Simply (UK) pay the remaining amount to First Step (IOM). First Step (IOM) pays a National Minimum 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.
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| 11 May 2023 | Simply Consulting Ltd | — | Removed by HMRC between April 2024 and May 2024 | |
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Address Simply Consulting Ltd, C/O CKM Consultants Ltd, 1ST Floor Queen Victoria House, 41-43 Victoria Street, Douglas, Isle of Man, IM1 2LF / Simply Umbrella Services Limited, C/O Begbies Traynor (Central) LLP, Suite 9 River Court, 5 West Victoria Dock Road, Dundee, DD1 3JT Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users sign a contract of employment and loan agreement with Simply (IOM). Simply (IOM) then enters into a contract with Simply (UK), a UK umbrella company, for the provision of the scheme user’s services. Simply (UK) 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 Simply (UK). Following the deduction of a fee, Simply (UK) pay the remaining amount to Simply (IOM). Simply (IOM) pays a National Minimum 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.
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| 11 May 2023 | Total Recruitment Services Ltd | — | Removed by HMRC between April 2024 and May 2024 | |
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Address Total Recruitment Services Ltd, C/o CKM Consultants Ltd, 1st Floor, Queen Victoria House, 41 - 43 Victoria Street, Douglas, Isle of Man, IM1 2LF / Contractor Central Accounting Ltd, The Axis Building Maingate, Team Valley Trading Estate, Gateshead, England, NE11 0NQ Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users sign a contract of employment and loan agreement with Total Recruitment Services Ltd (TRS). TRS then enters into a contract with Contractor Central Accounting Limited (CCAL), a UK umbrella company, for the provision of the scheme user’s services. CCAL 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 CCAL. Following the deduction of a fee, CCAL pay the remaining amount to TRS. TRS pays a National Minimum Wage salary to the scheme user and a payment, described as a loan and made pursuant to the loan agreement, which is made without deductions of Income Tax or National Insurance contributions.
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| 3 May 2023 | Buckingham Wealth Ltd | — | Currently named | |
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Address Buckingham Wealth Ltd (Belize), 1 Orchid Garden Street, Belmopan, Belize / Minerva Services Ltd (Belize), PO Box 445, Suite 5, Garden City Plaza, Mountainview Boulevard, Belmopan, Belize Named under Finance Act 2022 / Promoters of Tax Avoidance Schemes (POTAS)
How the scheme is claimed to work
Under the Umbrella Remuneration Trust (URT) arrangements, a scheme user (for example a 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.
Other information from HMRC
We have published a document that shows BWL and MSL (the ‘Promoters’) encouraging URT users to sign a declaration that claims the URT to which contributions were made is void, and HMRC must 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 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.
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| 20 April 2023 | Acacia Resourcing Services Limited | — | Removed by HMRC between March 2024 and April 2024 | |
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Address Stanmore House, 64-68 Blackburn Street, Manchester M26 2JS Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Users sign an employment contract with Acacia that says they will be paid at least the National Minimum Wage (NMW). Users also enter into an Option Grant Agreement with Acacia. Users submit timesheets to Acacia who invoice the end client or agency for the services the user has provided. Users are then paid a salary around NMW. After deducting an umbrella margin/administration charge and an additional fee in the region of 15%, Acacia pay the balance to the user, and this is supposedly for the grant of an option. This payment is claimed to be a capital payment and no tax or National Insurance is deducted.
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| 20 April 2023 | Marquee Ltd | — | Removed by HMRC between March 2024 and April 2024 | |
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Address The Charter Building, Charter Place, Uxbridge UB8 1JG Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
The arrangements involve users providing their services to end clients through Marquee Limited (ML). The users also sign an option grant agreement under which ML makes payments to users and users grant the right to ML, which if exercised, requires users to enter into an annuity agreement. The result is the remuneration for their services is artificially separated into a salary and payments made under the option grant agreement said to be in return for the option. No tax or National Insurance contributions are deducted in relation to the payments made under the option agreement.
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| 13 April 2023 | Focus Contractor Limited | — | Currently named | |
| 13 April 2023 | Peak PAYE Limited | — | Currently named | |
| 13 April 2023 | Purple Pay Limited | — | Currently named | |
| 2 March 2023 | Contractorcare Ltd | — | Currently named | |
| 2 March 2023 | PAYEme Ltd | — | Currently named | |
| 2 March 2023 | Saxonside Limited - Saxonside Option Grant | — | Currently named | |
| 23 February 2023 | Canopaye Limited | — | Currently named | |
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Address Canopaye Limited, The Charter Building, Charter Place, Uxbridge, UB8 1JG Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve users providing their services to end clients through CL. The 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 contributions are deducted in relation to the payments for the option.
Other information from HMRC
HMRC have previously published Spotlight 35 on disguised remuneration schemes involving annuity agreements based on a similar scheme.
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| 23 February 2023 | Integra Resourcing Limited | — | Currently named | |
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Address Integra Resourcing Limited, Block 12 Office M1 Suite 106, Tigne Place, Tigne Street, Sliema, Malta, SLM 7173 / Target Umbrella Limited, 6 Margaret Street, Newry, Northern Ireland, BT34 1DF Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Users sign separate employment contracts with IRL and TUL. Users also sign an ‘Overarching 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 payroll run, usually below £10, and a larger amount, described as a ‘loan’. The ‘loan’ amount is not taxed.
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| 7 February 2023 | Alpha Republic Limited | — | Removed by HMRC between December 2023 and January 2024 | |
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Address 85 Great Portland Street, London W1W 7LT Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users are paid their salary at the National Minimum Wage rate, which is subjected to tax and National Insurance contributions. They also receive a secondary payment which is not taxed, and is the balance of their contract value, minus the fees Alpha Republic Limited deduct for operating the scheme. Read more detail about how this scheme operates.
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| 19 January 2023 | Able Ltd | — | Removed by HMRC between December 2023 and January 2024 | |
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Address Able Ltd: 2nd Floor, Queen Victoria House, Victoria Street, Douglas, Isle of Man IM1 2LF / Contractor Central Accounting Ltd (CCAL): The Axis Building Maingate, Team Valley Trading Estate, Gateshead, England NE11 0NQ Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme user signs an employment contract and a ‘Commercial loan Agreement’ with Able, an umbrella company registered in the Isle of Man. CCAL, a UK based company, provides onshore support to Able. The user will submit timesheets to CCAL for the work they do for an end client /agency. CCAL will invoice the end client/agency for the user’s work and take receipt of payment from them. CCAL will transfer the payment to Able who then makes a salary payment to scheme users at a rate equivalent to the National Minimum Wage which is taxed, and a second payment, described as a loan, without tax and National Insurance contributions deducted.
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| 19 January 2023 | AML Tax (UK) Limited | — | Currently named | |
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Address 1st Floor, Blackfriars House, Parsonage, Manchester M3 2JA / 1st Floor, Blackfriars House, Parsonage, Manchester M3 2JA / 1st Floor Blackfriars, Parsonage, Manchester M3 2JA (address same for both promoters / suppliers) Named under Disclosure of Tax Avoidance Schemes (DOTAS) / Disclosure of Tax Avoidance Schemes (DOTAS) / Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
There is usually a pre-existing loan between a director/shareholder (the ‘scheme user’) and their 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 repayment. Therefore, the company does not pay Corporation Tax on the loan. An offshore company linked to AML creates and funds an employee benefit trust (EBT). The 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 Income Tax. The company also claims a Corporation Tax deduction for the amount of this assigned debt under employee costs. AML and Denmedical UK Limited promote the same scheme. A limited company splits the services 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 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.
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| 19 January 2023 | Tailored UK Services Ltd | — | Removed by HMRC between December 2023 and January 2024 | |
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Address 67 Grosvenor Street, Mayfair, London W1K 3JN Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users enter into an employment contract and a loan agreement with TUSL, providing their services to end clients, (sometimes through a recruitment agency). The employment contract provides that TUSL will pay the user a National Minimum Wage rate. The loan agreement with TUSL (Advance Deed) provides that TUSL will make an initial advance of up to £5,000 and further advances to the employee as they may think fit (Advance Payments). The Advance Payments are supposedly repayable within 18 months after receipt of the initial advance, but they are not repaid. TUSL invoices the recruitment agency or end client for the services carried out by the scheme users and retains between 10% to 12% of the invoiced amount, as their fee. Scheme users are then paid a salary with tax and National Insurance contributions (NICs) deducted, plus another payment under the ‘advance deed’ without deduction of Income Tax or NICs.
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| 24 November 2022 | Charteris Management Ltd | — | Currently named | |
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Address 1. Charteris Management Ltd of Manchester Business Park, 3000 Aviator Way, Manchester, M22 5TG. / 2. Taurus Limited of 3rd floor, Atlantic House, 4-8 Circular Road, Douglas, Isle of Man, IM1 1AG. / 3. Howe Consultancy Limited of 3rd floor, Atlantic House, 4-8 Circular Road, Douglas, Isle of Man, IM1 1AG. / 4. Griffith Anderson 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. Named under Finance Act 2022
How the scheme is claimed to work
The scheme users enter into an employment contract with CML, providing their services to end 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.
Other information from HMRC
CML claim the payment to the second party is an ‘introducer fee’. This is not the case and these payments can clearly be seen as the balance of 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.
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| 3 November 2022 | We PAYE Umbrella Limited | — | Removed by HMRC between September 2023 and November 2023 | |
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Address Scottish Provident Building, 7 Donegall Square West, Belfast BT1 6JH Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Users of the scheme would receive their gross contract value in 2 separate payments. The first element was a salary paid via WPUL. This was generally paid at National Minimum Wage (NMW) rate. The second payment was in the form of a loan. It did not go through PAYE and this payment was not taxed. Read more detail about how this scheme operates.
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| 29 September 2022 | Greenwich Contracts Ltd | — | Removed by HMRC between August 2023 and September 2023 | |
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Address Greenwich Contracts Ltd, 2 Eaton Gate, London SW1W 9BJ / Integra Resourcing Limited, Block 12 Office M1 Suite, 106 Tigne Place, Sliema SLM3173, Malta Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users are paid a National Minimum Wage (NMW) salary by GCL which is subject to tax and National Insurance Contributions (NICs). They also receive a second payment from IRL. This includes 2 elements: a small ‘bonus’ of around £10 which is paid through the payroll and subject to tax and NICs, and an additional amount which is not taxed and reflects the balance of their gross contract value, minus the fee deducted for operating the scheme. Read more detail about how this scheme operates.
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| 29 September 2022 | Nicely Paid Limited | — | Removed by HMRC between August 2023 and September 2023 | |
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Address Scottish Provident Building, 7 Donegall Square West , Belfast BT1 6JH Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Users of the scheme would receive their gross contract value in 2 separate payments. The first element was a salary paid via NPL. This was generally paid at National Minimum Wage (NMW). The second payment was by way of a loan. It did not go through PAYE and was made as a separate payment. Read more detail about how this scheme operates.
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| 31 August 2022 | Saxonside Limited | — | Removed by HMRC 4 September 2025 | |
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Address Saxonside Limited: Centaur House, Ancells Road, Fleet GU51 2UJ / Omni Contractors PCC Limited: Unit 2 Close Beg, Peel, Isle of Man IM5 1XF Named under Promoters of Tax Avoidance Schemes (POTAS) / Finance Act 2022
How the scheme is claimed to work
The scheme users enter into an employment contract with SAX and receive a share in OCP, a 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 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.
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| 31 August 2022 | The Umbrella Agency Limited | — | Currently named | |
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Address The Umbrella Agency Limited: The Colmore Building 20 Colmore Circus, Queensway, Birmingham, England, B4 6AT / Griffith Anderson Limited: 7 Bell Yard, London, England, WC2A 2JR Named under Finance Act 2022
How the scheme is claimed to work
The arrangements involve individuals providing their services to end clients through TUA and 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.
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| 18 August 2022 | Contractorcare Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address 24/25 The Shard, 32 London Bridge Street, London SE1 9SG Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Schemes users will sign a contract of employment along with a ‘Master Advance Agreement’. The intention of the scheme is the user will be paid a salary equivalent to that of National Minimum Wage and an un-taxed payment called an advance, meaning scheme users retain up to 84% of the expected gross contract earnings. Read more detail about how this scheme operates.
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| 18 August 2022 | Gateway Outsource Solutions Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address Gateway Outsource Solutions Ltd (GOS Malta), Block 12 Office M1 Suite, 112 Tigne Place, Tigne Street, Sliema, SLM 3173, Malta / Gateway Outsource Solutions Limited (GOS UK), Mottram House, 43 Greek Street, Stockport SK3 8AX Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
The scheme users enter into an employment agreement with GOS Malta. The users receive 2 salary payments, one paid at National Minimum Wage rate and a second payment which GOS UK describe as a loan or advance, which is not taxed. Read more detail about how this scheme operates.
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| 18 August 2022 | PAYEme Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address 3rd Floor 8 Princess Parade, Liverpool L3 1DL Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users will sign a contract of employment along with a ‘Master Advance Agreement’. The intention of the scheme is the user will be paid a salary equivalent to that of National minimum wage and an un-taxed payment called an ‘advance’, meaning scheme users retain up to 78% of the expected gross contract earnings. Read more detail about how this scheme operates.
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| 4 August 2022 | Industria PAYE Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address Greg’s Building, 1 Booth Street, Manchester M2 4DU Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users would receive their gross contract value in a payment made up of 2 separate elements. The first element was a National Minimum Wage salary that was taxed through PAYE. The second element was deemed to be in relation to an option grant agreement. This second element was not taxed. Read more detail about how this scheme operates.
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| 4 August 2022 | Pure Invoicing Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address Greg’s Building, 1 Booth Street, Manchester M2 4DU Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users would receive their gross contract value in a payment made up of 2 separate elements. The first element was a National Minimum Wage salary that was taxed through PAYE. The second payment was deemed to be in relation to an option grant agreement. The second element is not taxed. Read more detail about how this scheme operates.
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| 4 August 2022 | U R Group Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address Greg’s Building, Booth Street, Manchester M2 4DU Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Users of the scheme would receive their gross contract value in 2 separate payments . The first element was a salary paid via URGL. This was generally paid at National Minimum Wage, between £60 and £70 per day. The second payment was in the form of a loan. It did not go through PAYE and this payment was not taxed. Read more detail about how this scheme operates.
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| 7 July 2022 | Novus Consultants Limited (formerly Novus Limited) / Contractor Corner Accounting Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address Novus Consultants Limited (formerly Novus Limited): 1st floor, Queen Victoria House, Victoria Street, Douglas, IM1 2LF, Isle of Man / Contractor Corner Accounting Limited: Suite 1, Plymouth House, Plymouth Road, Blackpool FY3 7JS, England Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Schemes users sign an employment contract and a ‘Commercial Loan Agreement’ (CLA) with NOL. The user will be paid a salary based on National Minimum Wage that is taxed, and a second payment that is not taxed under the CLA. NOL retains around 20% of the gross contract earnings. Read more detail about how this scheme operates.
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| 7 July 2022 | Paybox Umbrella Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address PUL UK: Building 3, City West Business Park, Gelderd Road, Leeds LS12 6LN / PUL Malta: Vincenti Buildings, 28/19 (suite no 1862), Strait Street, Valletta, Malta Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
Scheme users enter into an employment agreement with PUL Malta. Users receive 2 payments from PUL Malta, one paid at National Minimum Wage rate and a second payment which is not declared for tax. Read more detail about how this scheme operates.
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| 7 July 2022 | T2 Outsourcing Limited | — | Removed by HMRC between June 2023 and August 2023 | |
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Address Unit 5, Connect Business Village, Derby Road, Liverpool L5 9PR Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
The scheme user enters an employment contract with T2 who make composite payments to the scheme users for services provided by the user. The first element is a National Minimum Wage salary that is subjected to tax and National Insurance contributions, and a secondary element described as an ‘advance drawdown’ which is not. Read more detail about how this scheme operates.
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| 7 April 2022 | Absolute Outsourcing Limited | — | Removed by HMRC between February 2023 and June 2023 | |
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Address Fernhills House, Foerster Chambers, Todd Street, Bury, Greater Manchester BL9 5BJ Named under Disclosure of Tax Avoidance Schemes (DOTAS)
How the scheme is claimed to work
The users completed an advance deed along with their employment contract. This advance deed is intended to justify the user receiving non taxable advance payments along with a National Minimum Wage salary. The aggregate payments amount to around 82% of their gross contract earnings. Read more detail about how this scheme operates.
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| 7 April 2022 | Equity Participation Scheme (EPS) / Purple Pay Limited (PPL) | — | Removed by HMRC between April 2022 and July 2022 | |
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Address 70 Gracechurch Street, London, EC3V 0HR |
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| 7 April 2022 | Purple Pay Limited / Equity Participation Scheme | — | Removed by HMRC between July 2022 and August 2022 | |
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Address 70 Gracechurch Street, London, EC3V 0HR
How the scheme is claimed to work
PPL invoice and receive payment from the end user. PPL pay the user around 5% of this amount as wages which is taxed under Pay As You Earn (PAYE). PPL pay around 75% of this amount as an advance to the user under the employee cash flow facility. This amount is not taxed under PAYE. PPL retain around 20% of the amount as their fee. Read more detail about how this scheme operates.
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Source: HMRC, GOV.UK. Last checked 27 August 2026, 16:05.
HMRC removes an entry one year after naming it. FCSA does not — entries removed by HMRC remain here, marked as removed.
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