Dacă folosiți oricare dintre schemele prezentate pe liste sau scheme similare, HMRC vă sfătuiește insistent să vă retrageți din ele și să vă rezolvați problemele fiscale pentru a preveni acumularea unei datorii fiscale mari.
Dacă sunteți implicat în oricare dintre schemele de evitare a taxelor prezentate pe această pagină, sau recunoașteți oricare dintre promotori, intermediari, sau furnizori, trebuie să contactați HMRC cât mai curând posibil.
Există și alte scheme, promotori, intermediari și furnizori despre care HMRC nu poate publica informații în acest moment. Acest lucru se poate datora faptului că:
HMRC colectează informații despre promotor, intermediar, furnizor sau despre schemele de evitare a taxelor care sunt promovate
HMRC ia în considerare reprezentările unui promotor, intermediar sau furnizor
perioada de apel pentru ne retragerea unui stop notice nu s-a încheiat
HMRC nu are cunoștință despre schema de evitare a taxelor, promotor, intermediar sau furnizor
Dacă doriți să obțineți mai multe informații despre o companie sau directorii acesteia, puteți verifica Companies House.
Puteți raporta online la HMRC schemele de evitare a taxelor și persoanele care vă oferă aceste scheme, folosind serviciul report tax fraud or avoidance. Puteți trimite acest formular anonim. Nu trebuie să vă dați numele, adresa sau emailul.
Lista schemelor de evaziune fiscală, a promotorilor, intermediarilor și furnizorilor
This is part of the alphabetical list of named tax avoidance schemes, promoters, enablers and suppliers.
ABC Umbrella Ltd
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
ABC Umbrella Ltd / Kevin Cutler (Director of ABC Umbrella Ltd) / Krevit Ltd (Incorporated in Cyprus) / Giannakis Fysentzou (Director of Krevit Ltd)
Addresses of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
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
Date of publication
9 August 2023
Last updated
22 May 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Abchurch Ltd
Details of persons suspected of promoting the scheme
Abchurch Ltd
Addresses of persons suspected of promoting the scheme
128 City Road, London, EC1V 2NX
Date of publication
29 February 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Acacia Management Services Limited
Name of promoter of scheme and connected person
Acacia Management Services Limited (AMS) / Jake Hamill (former director of Acacia Management Services Limited)
Address of promoter of scheme
27 Byrom Street, Manchester, M3 4PF / Former address: Office 2.24 Edward Pavilion, Albert Dock, Liverpool, L3 4AF
Date of publication
11 April 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Accent Umbrella Ltd
Details of persons suspected of promoting the scheme
Accent Umbrella Ltd (AUL)
Addresses of persons suspected of promoting the scheme
Unit 1-3 Salisbury Street, Widnes, WA8 6PJ / Previous address: 20-22 Wenlock Road, London N1 7GU
Date of publication
9 May 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Acquda Limited
Details of persons suspected of promoting the scheme
Acquda Limited (AL)
Addresses of persons suspected of promoting the scheme
45-55 Commercial Street, London, E1 6BD
Date of publication
8 August 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Acquda Solutions Limited
Details of persons suspected of promoting the scheme
Acquda Solutions Limited (ASoL)
Addresses of persons suspected of promoting the scheme
50 Princes Street, Ipswich, IP1 1RJ
Date of publication
5 December 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Adapt Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Adapt Limited (Based in Isle of Man) / David Michael Yeomans (director of Adapt Limited) / Frank Umbrella Limited (in liquidation) / TGI Payday Limited
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Agile Pay Ltd
Name of promoter
Agile Pay Ltd
Date arrangements subject to Stop Notice published
21 March 2024
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme
AIT Umbrella Limited (AIT) (Company Registration Number 10943923)
Addresses of persons suspected of promoting the scheme
Bromsgrove Enterprise Park, Isidore Road, Bromsgrove, Worcestershire, B60 3ET
Date of publication
14 August 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Alphasaint Ltd
Details of persons suspected of promoting the scheme
Alphasaint Ltd (ASL)
Addresses of persons suspected of promoting the scheme
71-75 Shelton Street, London, England, WC2H 9JQ
Date of publication
11 April 2024
Information updated
5 September 2024
Scheme reference number (SRN)
93135363
Date SRN allocated to the scheme
16 May 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
AML Tax (UK) Limited
We have published details of 3 schemes that have been supplied and/or promoted by AML Tax (UK) Limited:
a scheme utilising an annuity arrangement
a scheme utilising an employee benefit trust (EBT)
a scheme utilising a split contract
AML Tax (UK) Limited — Annuity Arrangements
Name of scheme
Annuity Arrangements
Name of promoter or supplier of scheme
AML Tax (UK) Limited (AML)
Address of promoter or supplier of scheme
1st Floor, Blackfriars House, Parsonage, Manchester M3 2JA
Date of publication
19 January 2023
Scheme reference number (SRN)
64011522
Date SRN allocated to the scheme
19 May 2022
Legislation under which this scheme/promoter has been named
Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based
Section 455 of the Corporation Tax Act 2010 (CTA)
How the scheme is claimed to work — summary
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.
1st Floor, Blackfriars House, Parsonage, Manchester M3 2JA
Date of publication
19 January 2023
Scheme reference number (SRN)
71821313
Date SRN allocated to the scheme
19 May 2022
Legislation under which this scheme/promoter has been named
Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based
Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work — summary
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 Tax (UK) Limited (AML) / Denmedical UK Limited
Address of promoters or suppliers of scheme
1st Floor Blackfriars, Parsonage, Manchester M3 2JA (address same for both promoters / suppliers)
Date of publication
19 January 2023
Scheme reference number (SRN)
15062269
Date SRN allocated to the scheme
28 July 2022
Legislation under which this scheme/promoter has been named
Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based
Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work — summary
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.
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
Apricot Umbrella Limited (AUL) / Mr Brian Ash (Former director of Apricot Umbrella Limited) / ADYE Ltd (Based in Cyprus) / Giannakis Fisentzou (Director of ADYE Ltd)
Addresses of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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’.
Arrow Tree Consulting Limited
Details of persons suspected of promoting the scheme
Arrow Tree Consulting Limited (Company number 15424716)
Addresses of persons suspected of promoting the scheme
85 Great Portland Street, First Floor, London, England, W1W 7LT
Date of publication
5 June 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Astra Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Astra Limited (Based in Isle of Man) / David Coyle (director of Astra Limited) / TGI Payday Limited
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
B2BTradecard Limited
Details of persons suspected of promoting the scheme or having any other role in relation to making the scheme available for implementation
(Promoter:) 1. B2BTradecard Limited (B2B) / (Any Other Role:) 2. Harrison Beale & Owen Management Services Limited (HBOMS) / 3. HB&O Ltd (Previously known as Harrison Beale & Owen Limited) (HBOL) / 4. SPM Management Consultancy Ltd (SPMCL) / 5. Ojak Consultancy Limited (Trading as Certax Basingstoke) (OCL) / 6. Atlas Accountancy Limited (AAL) / 7. Henry Bramall & Co Limited (HBC) / 8. Roelken Limited (RL)
Addresses of persons suspected of promoting the scheme or having any other role in relation to making the scheme available for implementation
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
Date of publication
18 July 2024
Last updated
18 September 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Back Office Assistance 1 Limited
Details of persons suspected of promoting the scheme
Back Office Assistance 1 Limited (BOA1L)
Addresses of persons suspected of promoting the scheme
167-169 Great Portland Street, London, W1W 5PF
Date of publication
10 April 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Back Office Services 1 Limited
Details of persons suspected of promoting the scheme
Back Office Services 1 Limited (BOS1L)
Addresses of persons suspected of promoting the scheme
167-169 Great Portland Street, London, W1W 5PF
Date of publication
10 April 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Back Office Systems 1 Limited
Details of persons suspected of promoting the scheme
Back Office Systems 1 Limited (BOSYSL)
Addresses of persons suspected of promoting the scheme
7 Bell Yard, Bell Yard, London, England, WC2A 2JR
Date of publication
1 May 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Balance Bay Limited
Details of persons suspected of promoting the scheme
Balance Bay Limited (BBL) (in liquidation)
Addresses of persons suspected of promoting the scheme
Previous address: Office 5272, 321-323 High Road, Romford, RM6 6AX
Date of publication
8 August 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Balance Bay Services Limited
Details of persons suspected of promoting the scheme
Balance Bay Services Limited (BBSL)
Addresses of persons suspected of promoting the scheme
7 Bell Yard, London, WC2A 2JR
Date of publication
7 November 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Blizzard Pay Ltd
Details of persons suspected of promoting the scheme
Blizzard Pay Ltd (BPL)
Addresses of persons suspected of promoting the scheme
20 Wenlock Road, London, N1 7GU
Date of publication
25 July 2024
Last updated
24 July 2025
Scheme reference number (SRN)
03131798
Date SRN Allocated to the Scheme
11 March 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Bluemoore Associates Ltd
Details of persons suspected of promoting the scheme, or of being a connected person
Bluemoore Associates Ltd (BAL) /Oliver Jenner (Sole director of BAL)
Addresses of promoters suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.’
Bluestar Financial Solutions Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Bluestar Financial Solutions Limited / Steven Alan Carridge (Director of Bluestar Financial Solutions Limited)
Address of promoters suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
HMRC have previously published Spotlight 60 on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies.
The Brightest Future Limited
Details of persons suspected of promoting the scheme
The Brightest Future Limited (Company number 14836170)
Addresses of persons suspected of promoting the scheme
The Mclaren Building, 46, The Priory, Queensway, Birmingham, B4 7LR
Date of publication
29 May 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Buckingham Wealth Ltd
We have published entries that relate to 2 schemes operated by Buckingham Wealth Ltd:
scheme 1 — published under Finance Act 2022
scheme 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Name of promoter or supplier of scheme
Buckingham Wealth Ltd (BWL) (incorporated in Belize) / Minerva Services Ltd (MSL) (incorporated in Belize)
Address of promoter or supplier of scheme
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
Date of publication
3 May 2023
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Documents which are appropriate to publish
Please find below a link to the page for published documents, including the document issued by the Promoters to clients — the document contains a summary of the Nova arrangement and a question-and-answer section. HMRC do not agree with the assertions made in this document. We are publishing it to aid understanding of how Nova is claimed to work; to demonstrate that the Promoters do not appear to believe their own tax avoidance scheme works; and to deter potential scheme users from trusting the claims made by these Promoters. Evidence of marketing material used by tax avoidance promoters and suppliers.
Scheme entry
2
Name of promoter
Buckingham Wealth Ltd (incorporated in Belize)
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
10 November 2023
Date name of promoter subject to Stop Notice published
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Calculate Limited
Details of persons suspected of promoting the scheme
Calculate Limited
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Canopaye Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Canopaye Limited (CL) / Philip Jackson (director of Canopaye Limited) / Niall Bradley (previous director of Canopaye Limited)
Addresses of promoters suspected of promoting the scheme
Canopaye Limited, The Charter Building, Charter Place, Uxbridge, UB8 1JG
Date of publication
23 February 2023
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
HMRC have previously published Spotlight 35 on disguised remuneration schemes involving annuity agreements based on a similar scheme.
Century Umbrella Limited
Details of persons suspected of promoting the scheme
Century Umbrella Limited
Addresses of persons suspected of promoting the scheme
Third Floor, 207 Regent Street, London, W1B 3HH
Date of publication
7 November 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Charteris Management Ltd
Details of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation
Addresses of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation
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.
Date of publication
24 November 2022
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Clear Water Administration Limited
Details of persons suspected of promoting the scheme
Clear Water Administration Limited (CWA)
Addresses of persons suspected of promoting the scheme
Level One Basecamp, Liverpool, 49 Jamaica Street, Liverpool, L1 0AH
Date of publication
28 November 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Compas Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Compas Limited (incorporated in the Isle of Man) / Ernest Umbrella Limited (in liquidation) / Imagine Umbrella Limited / Jessica Anne Mahoney (former Compas Limited director) / Martina Parlato (former Compas Limited director) / Stephen Charles Biggs (Ernest Umbrella Limited director) / Ross Plowman (Imagine Umbrella Limited director)
Addresses of persons suspected of promoting the scheme
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
Date of publication
22 May 2025
Legislation under which this scheme/promoter has been named
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.
Complete Payment Solutions Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Compliant Pay Ltd
Details of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation
Compliant Pay Ltd / Ultimate Planning Ltd
Addresses of promoters suspected of promoting the scheme and addresses of those suspected of having any other role in relation to making the scheme available for implementation
Ultimate Planning Ltd: 128 City Road, London, EC1V 2NX
Date of publication
28 June 2023
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Connection Point Ltd
Details of persons suspected of promoting the scheme
Connection Point Ltd (CPL)
Addresses of persons suspected of promoting the scheme
Dept 4408, 196 High Road, London, N22 8HH
Date of publication
26 September 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Consortius Solutions Limited
Details of persons suspected of promoting the scheme
Consortius Solutions Limited (CSL)
Addresses of promoters suspected of promoting the scheme
128 City Road, London, EC1V 2NX
Date of publication
7 November 2024
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Contractor Bureau Limited
We have published 2 entries that relate to a scheme operated by Contractor Bureau Limited:
entry 1 — published under Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime (POTAS)
Scheme entry
1
Details of persons suspected of promoting the scheme, or of being a connected person
Contractor Bureau Limited (CBL) / Emmanuel Forkuoh (Director of CBL)
Addresses of persons suspected of promoting the scheme
16 Upper Woburn place, London, WC1H 0AF
Date of publication
14 March 2024
Legislation under which this scheme/promoter has been named
Finance Act 2022
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
14 November 2024
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme
Countrywide Partners Limited (CPL)
Addresses of persons suspected of promoting the scheme
Suite 114, 25 Goodlass Road, Liverpool L24 9HJ
Date of publication
2 August 2023
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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’.
Cube Umbrella Limited
Name of promoter of scheme and connected persons
Cube Umbrella Limited (CUL) / Robert Charlesworth (Director of CUL)
Address of promoter of scheme
Fern Hill Business Centre, Foerster Chambers, Todd Street, Bury, Greater Manchester, England, BL9 5BJ
Date of publication
6 June 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Dalespay Ltd
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
Dalespay Ltd (DL) / Austin Merritt (Director of DL) / Bestia Holdings Ltd (BHL) (Incorporated in Cyprus) / Giannakis Fysentzou (Director of BHL)
Addresses of persons suspected of promoting the scheme or having any other role in relation to making the scheme available for implementation
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies.
Earneze Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Earneze Limited / William Donald Turner — also known as William Donald Menzies Turner (Director of Earneze Limited)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Easyway Umbrella Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Easyway Umbrella Limited
Addresses of promoters suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Edge Umbrella Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Edge Umbrella Limited (EUL) / Darren Harding (Director of EUL / Joanna Fysentzou (former Director of EUL) / Deposlo Holdings Ltd (based in Cyprus) / Giannakis Fisentzou (Director of Deposlo Holdings Ltd)
Addresses of promoters suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Employe Limited
Details of persons suspected of promoting the scheme
Employe Limited (EL) (in liquidation)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Employe US Limited
Details of persons suspected of promoting the scheme
Employe US Limited (EUL)
Addresses of persons suspected of promoting the scheme
7 Bell Yard, London, WC2A 2JR
Date of publication
10 October 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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 appears 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.
Everest Contracting Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Everest Contracting Limited / Mr Jack McConnell (former Director of Everest Contracting Limited)
Addresses of persons suspected of promoting the scheme
Blinkbox Business Complex, Western Road, Deal, Kent, CT14 6PJ
Date of publication
5 September 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Evolve Payroll Ltd
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
Evolve Payroll Ltd (EPL) (Company number 15158959) / Richard Douglas Holder (Director of EPL)
Addresses of persons suspected of promoting the scheme
EPL: 4 Spur Road, Cosham, Portsmouth, United Kingdom, PO6 3EB
Date of publication
31 July 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Excala Solutions Limited
Details of persons suspected of promoting the scheme
Excala Solutions Limited (ESL)
Address of promoters suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Expertise Solutions Limited
Details of persons suspected of promoting the scheme
Expertise Solutions Limited
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Fast Payroll UK Ltd
Details of persons suspected of promoting the scheme, or of being a connected person
Fast Payroll UK Ltd (FPUK) — trading as Fastpay / Kieran Elliott (Director of FPUK)
Addresses of persons suspected of promoting the scheme
167-169 Great Portland Street, London, W1W 5PF
Date of publication
22 August 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
1st Choice Umbrella Ltd
Name of promoters
1st Choice Umbrella Ltd and Omni Contractors PCC Limited
Date arrangements subject to Stop Notice published
12 September 2024
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme
First Paye Consultants Limited (FPCL)
Addresses of promoters suspected of promoting the scheme
Former address: 20 Chapel Street, Liverpool, L3 9AG
Date of publication
5 December 2024
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Flex Payroll and Accounting Services Ltd
We have published 2 entries that relate to a scheme operated by Flex Payroll and Accounting Services Ltd:
entry 1 — published under Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Name of scheme
FlexPAS Advance payment
Name of promoter of scheme and connected persons
Flex Payroll and Accounting Services Ltd (Flex PAS) / Russell Lee Forshaw (former Director of Flex PAS)
Address of promoter of scheme
Flex Payroll and Accounting Services Ltd, Stapeley House, London Road, Stapeley, Nantwich, England, CW5 7JW
Date of publication
1 February 2024
Legislation under which this scheme/promoter has been named
Finance Act 2022
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
6 March 2025
Date name of promoter subject to Stop Notice published
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
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
Date of publication
18 Sept 2025
Scheme Reference Number (SRN)
36384646
Date SRN allocated to the scheme
29 November 2024
Legislation under which this scheme/promoter has been named
Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based
Part 7A of ITEPA 2003 – Employment income provided through third parties
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.
GL Platinum Ltd
Details of persons suspected of promoting the scheme, or of being a connected person
GL Platinum Ltd (formerly known as GL Premier 02 Ltd) (Company number 13918832) / GL Premier Ltd (Company number 12996993) / Mr Charles Barlow (Director of GL Premier Ltd and former director of GL Platinum Ltd)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
It is HMRC’s view that the ‘Retained Profit’ payments made by both GL Premier Ltd and GL Platinum Ltd to their employees should be subject to Income Tax and NICs. HMRC suspect that most GL Premier Ltd scheme users were moved to GL Platinum Ltd as a successor to the GL Premier arrangements. Both GL Premier Ltd and GL Platinum Ltd have a director in common, Charles Barlow. Charles Barlow is also a director of Langan Scott and Co Ltd, whom HMRC published on the ‘Current list of named tax avoidance schemes, promoters, enablers and suppliers’ webpage on 19 September 2024. HMRC advise employees of both GL Premier Ltd and GL Platinum Ltd to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted from their income.
GL Premium Ltd
Details of persons suspected of promoting the scheme
GL Premium Ltd (GLPL)
Addresses of persons suspected of promoting the scheme
7 Bell Yard, London, WC2A 2JR
Date of publication
3 October 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Goldfish Umbrella Limited
We have published 2 entries that relate to a scheme operated by Goldfish Umbrella Limited:
entry 1 — published under Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Name of scheme
Goldfish Umbrella Limited
Details of persons suspected of promoting the scheme
Goldfish Umbrella Limited (GUL)
Address of persons suspected of promoting the scheme
Kemp House, 152-160 City Road, London, EC1V 2NX
Date of publication
16 May 2024
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
12 September 2024
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme, or of being a connected person or having any other role in relation to making the scheme available for implementation
Greenlight Payroll Services Limited (GPS) / Robert Dixey (Director of GPS) / Greenlight Payroll Operations Ltd (in liquidation) / Dynasty Payroll Solutions Ltd
Addresses of promoters suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation
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
Date of publication
28 November 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Hamilton Bradbury Ltd
Name of promoter or supplier of scheme
Hamilton Bradbury Ltd (HBL) (registered in the UK)
Addresses of promoters suspected of promoting the scheme
Hamilton Bradbury Ltd, Pacific House, Relay Point, Wilnecote, Tamworth, Staffordshire, B77 5PA
Date of publication
25 September 2023
Scheme reference number (SRN)
81003536
Date SRN allocated to the scheme
28 February 2023
Legislation under which this scheme/promoter has been named
Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based
Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work — summary
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.
Details of persons suspected of promoting the scheme, or of being a connected person
Head Restart Limited (HRL) (Company number 15432663) / Mr Stephen Thomas Kane (Director of HRL)
Addresses of persons suspected of promoting the scheme
HRL: Suite 2a Blackthorn House, St Pauls Square, Birmingham, B3 1RL
Date of publication
12 June 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Hive Umbrella Ltd
Name of promoter or supplier of scheme
Hive Umbrella Ltd
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
10 November 2023
Date name of promoter subject to Stop Notice published
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Infrapro Consulting Ltd
Details of persons suspected of promoting the scheme
Infrapro Consulting Ltd (ICL)
Address of person suspected of promoting the scheme
4 Admiral Way, Doxford International Business Park, Sunderland, United Kingdom, SR3 3XW
Date of publication
26 September 2024
Last updated
4 September 2025
Scheme Reference Number (SRN)
04584462
Date SRN allocated to scheme
20 March 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Integra Resourcing Limited
Name of promoter or supplier of scheme
Integra Resourcing Ltd — registered in Malta (IRL) / Target Umbrella Ltd — registered in the UK (TUL)
Address of promoter or supplier of scheme
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
Date of publication
23 February 2023
Scheme reference number (SRN)
79326711
Date SRN allocated to the scheme
12 August 2022
Legislation under which this scheme/promoter has been named
Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based
Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work — summary
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.
Innovate Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Innovate Limited (IL) — Registered in the Isle of Man (in liquidation) / Jolene Cowell (Director of IL) / James Paul McAllister (Director of IL) / Frank Umbrella Limited (FUL) (in liquidation) / Contractor Corner Accounting Limited (CCA) (in liquidation)
Addresses of promoters suspected of promoting the scheme
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)
Date of publication
5 September 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Intu Solutions Limited
Details of persons suspected of promoting the scheme
Intu Solutions Limited (ISL)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
IP Global Consulting Ltd
Details of persons suspected of promoting the scheme
IP Global Consulting Ltd (IPG)
Addresses of promoters suspected of promoting the scheme
Registered office: 63-66 Hatton Garden, London, EC1N 8LE / Trading address: 54 St. James Street, Liverpool, L1 0AB
Date of publication
9 August 2023
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Jigsaw Payment Solutions Limited
Details of persons suspected of promoting the scheme
Jigsaw Payment Solutions Limited (JPSL) trading as Jigsaw Pay
Addresses of persons suspected of promoting the scheme
2a Connaught Avenue, London, E4 7AA
Date of publication
21 November 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Just Standard Limited
Details of persons suspected of promoting the scheme
Just Standard Limited (JSL)
Addresses of persons suspected of promoting the scheme
71-75, Shelton Street, London, WC2H 9JQ
Date of publication
3 October 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
K & B Umbrella Ltd
Details of persons suspected of promoting the scheme
K & B Umbrella Ltd (also known as Knight and Bishop Services, and Knight & Bishop) (Company number 14581885)
Addresses of persons suspected of promoting the scheme
International House, 307 Cotton Exchange, Old Hall Street, Liverpool, United Kingdom, L3 9LQ
Date of publication
3 April 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Knights Network Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Knights Network Limited (KNL) / Enya Anson — also known as Enya Elizabeth Torres and Enya Elizabeth Torres-Anson (Director of KNL)
Addresses of persons suspected of promoting the scheme
KNL, (as of 14 November 2024) Dept 4972a 43 Owston Road, Carcroft, Doncaster DN6 8DA / Previous address: 196 High Road, London, England, N22 8HH
Date of publication
24 July 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Langan Scott and Co Ltd
Details of persons suspected of promoting the scheme
Langan Scott and Co Ltd (LSCL)
Addresses of persons suspected of promoting the scheme
167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF
Date of publication
19 September 2024
Information updated
7 November 2024
Scheme reference number (SRN)
09322856
Date SRN allocated to the scheme
5 September 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Less Tax For Landlords Limited
Name of scheme
Mixed partnership (Hybrid business model)
Name of promoter or supplier of scheme
Less Tax For Landlords Limited (LT4L) / OCG Accountants Ltd (OCGAL)
Address of promoter or supplier of scheme
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
Date of publication
24 July 2025
Scheme reference number (SRN)
48700230
Date SRN allocated to the scheme
6 August 2024 (notified 13 August 2024)
Legislation under which this scheme/promoter has been named
Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based
The statutory provisions relating to Income Tax, Capital Gains Tax, Stamp Duty Land Tax and Inheritance Tax.
How the scheme is claimed to work — summary
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.
More detail about how this scheme operates
HMRC has published Spotlight 63. This provides information on the kind of taxes the above schemes may seek to avoid.
Level Up Associates Limited
Details of persons suspected of promoting the scheme
Level Up Associates Limited (LUA)
Addresses of persons suspected of promoting the scheme
7 Bell Yard, London, WC2A 2JR
Date of publication
27 February 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
LWI Services Limited
Name of promoter
LWI Services Limited
Address of promoter
Rodus Building 4th Floor, Road Reef PO Box 765, Road Town, Tortola, British Virgin Islands
Date arrangements subject to Stop Notice published
17 October 2024
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme
Masterstroke Solutions Limited
Addresses of persons suspected of promoting the scheme
128 City Road, London, EC1V 2NX
Date of publication
16 January 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Medbridge Ltd
Details of persons suspected of promoting the scheme
Medbridge Ltd
Addresses of persons suspected of promoting the scheme
Former Address: Suite 2a, Blackthorn House, St Pauls Square, Birmingham, B3 1RL
Date of publication
30 January 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Minerva Services Ltd
Name of scheme
Nova
Name of promoter or supplier of scheme
Minerva Services Ltd (formerly incorporated in Belize)
Address of promoter or supplier of scheme
PO Box 445, Suite 5 Garden City Plaza, Mountainview Boulevard, Belmopan, Belize
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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, JJDM have a role in relation to making available the scheme promoted by ML by acting as marketing and sales agents for ML and by introducing workers to ML in accordance with a brokerage agreement. HMRC advise recruitment agents and others contacted by these companies on behalf of umbrella companies to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax will be deducted from any income paid by the umbrella companies.
Miwsa Management Ltd
Details of persons suspected of promoting the scheme
Miwsa Management Ltd (MML)
Addresses of persons suspected of promoting the scheme
7 Bell Yard, London, WC2A 2JR
Date of publication
3 October 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
MLG Pay Limited
We have published 2 entries that relate to one scheme operated by MLG Pay Ltd:
entry 1 — published under the Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Details of persons suspected of promoting the scheme
MLG Pay Limited (MLG)/ Setu Kamal (Barrister)
Addresses of persons suspected of promoting the scheme
MLG: Suite 101, 89 High Street, Sidcup, DA14 6DW
Date of publication
21 December 2023
Last updated
4 September 2025
Legislation under which this scheme/promoter has been named
Finance Act 2022
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’.
Any other information HMRC considers relevant to publish about these schemes
HMRC’s view is that both elements of the payment should be treated as ‘normal income/as the user’s salary’, and is 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 MLG to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. 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. HMRC suspects Setu Kamal is responsible for the design of the scheme arrangements and has created and supplied contract and agreement templates which are integral to the implementation of the relevant arrangements.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
18 April 2024
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme, or of being a connected person
Modus Umbrella Limited (Company number 13011077) / Mark Anthony James O’Donnell (Director of Modus Umbrella Limited)
Addresses of persons suspected of promoting the scheme
Modus Umbrella Limited: 2 Falcon Gate, Welwyn Garden City, Hertford, Hertfordshire, AL7 1TW
Date of publication
31 July 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Mountain View Admin Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Mountain View Admin Limited / Mountain View Administration Limited / Mr John O’Malley (Director of Mountain View Administration Limited)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
New Mill Resourcing Ltd
Details of persons suspected of promoting the scheme, or of being a connected person
New Mill Resourcing Ltd / Suresh Kumar (Director of New Mill Resourcing Ltd)
Addresses of persons suspected of promoting the scheme
85 Great Portland Street, London, England, W1W 7LT
Date of publication
18 July 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
NM Recruitment Services Ltd
Details of persons suspected of promoting the scheme
NM Recruitment Services Ltd (NMRSL) (in liquidation since 27 March 2025)
Addresses of persons suspected of promoting the scheme
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
Date of publication
22 May 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Odyssey Payroll Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Odyssey Payroll Limited (OPL) / Jonathan Malyon (Director of Odyssey Payroll Limited)
Addresses of persons suspected of promoting the scheme
28 Baddow Road, Chelmsford, England, CM2 0DG
Date of publication
5 September 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Olympus Contracting Limited
We have published 2 entries that relate to this scheme operated by Olympus Contracting Limited:
entry 1 — published under the Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Details of persons suspected of promoting the scheme, or of being a connected person
Olympus Contracting Limited (OCL) / Jordan Dobney (former director of OCL) / Oliver Ames — sole director of OCL
Addresses of promoters suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
Finance Act 2022
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.
Any other information HMRC considers relevant to publish about these schemes
HMRC have previously published Spotlight 45 and Spotlight 60 guidance on disguised remuneration schemes involving umbrella companies based on similar arrangements.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
7 December 2023
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme, or of being a connected person
On the Box Pay Ltd (OTBP)
Addresses of persons suspected of promoting the scheme
Blinkbox Business Complex, Western Road, Deal, Kent, CT14 6PJ
Date of publication
8 August 2024
Last updated
22 May 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Optima Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Optima Limited (Optima) — Registered in the Isle of Man (in liquidation) / Anthony Pithers (Director of Optima) / Frank Umbrella Limited (FUL) (in liquidation) / Contractor Corner Accounting Limited (CCA) (in liquidation)
Addresses of promoters suspected of promoting the scheme
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)
Date of publication
5 September 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Paul Baxendale-Walker
We have published the details of 2 stop notices that were issued to Paul Baxendale-Walker under the Promoters of Tax Avoidance Schemes (POTAS) regime.
Stop Notice entry
1
Name of promoter
Paul Baxendale-Walker
Date arrangements subject to Stop Notice published
15 May 2025
Date name of promoter subject to Stop Notice published
We have published 2 entries that relate to this scheme operated by PAYE Services Ltd:
entry 1 — published under the Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Details of persons suspected of promoting the scheme, or of being a connected person
PAYE Services Limited (PSL) / Simon Peter Whitehead (Director of PSL)
Addresses of promoters suspected of promoting the scheme
PAYE Services Limited, 7 Bell Yard, London, WC2A 2JR
Date of publication
28 June 2023
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
27 July 2023
Date name of promoter subject to Stop Notice published
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
HMRC have previously published Spotlight 60 guidance on disguised remuneration schemes.
Pay APL Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Pay APL Limited (PAL) (Company number 15860821) / Mr Donal Tobin (Director of PAL)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Pay Rec Limited
Details of persons suspected of having any other role in relation to making the scheme available for implementation.
Pay Rec Limited (PRL)
Addresses of persons suspected of having any other role in relation to making the scheme available for implementation
1 Piccadilly Business Centre, Aldow Enterprise Park, Manchester, United Kingdom, M12 6AE
Date of publication
31 August 2023
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Payroll Professors Limited
Details of persons suspected of promoting the scheme
Addresses of persons suspected of promoting the scheme
7 Bell Yard, London, WC2A 2JR
Date of publication
13 March 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Paystone Services Limited
Details of persons suspected of promoting the scheme
Paystone Services Limited (PSL) (also known as Artifact Services)
Addresses of persons suspected of promoting the scheme
48 West George Street, Clyde Offices, 2nd Floor, Glasgow, Scotland, G2 1BP
Date of publication
1 February 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Pazepay Limited
Details of persons suspected of promoting the scheme
Pazepay Limited (PPL)
Addresses of persons suspected of promoting the scheme
20 Colmore Circus, Queensway, Birmingham, B4 6AT
Date of publication
29 August 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Peak PAYE Limited
Name of promoter
Peak PAYE Limited
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
13 April 2023
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme
Penhale Solutions Limited (PSL)
Addresses of promoters suspected of promoting the scheme
Former address: 71-75 Shelton Street, London, WC2H 9JQ / Current Address (as of 25 September 2024): 128 City Road, London, EC1V 2NX
Date of publication
16 January 2025
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Pinnacle and Partners Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Pinnacle and Partners Limited / Omni Contractors PCC Limited (OCP) / Enya Elizabeth Torres (Director of Pinnacle and Partners Limited) / Mr Paul Middleton (Director of OCP)
Addresses of persons suspected of promoting the scheme
Pinnacle and Partners Limited: 27 Old Gloucester Street, London, WC1N 3AX / OCP: Unit 2 Close Beg, Peel, Isle of Man IM5 1XF
Date of publication
23 January 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Prime Umbrella Services Ltd
We have published 2 entries that relate to this scheme operated by Prime Umbrella Services Ltd:
entry 1 — published under the Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
Prime Umbrella Services Ltd / Adam Whitehead (Director of Prime Umbrella Services Ltd) / Wilson Costello Limited / Jonathan Milne (Director of Wilson Costello Limited)
Addresses of persons suspected of promoting the scheme
Prime Umbrella Services Ltd, 128 City Road, London, United Kingdom, EC1V 2NX
Date of publication
31 August 2023
Legislation under which this scheme/promoter has been named
Finance Act 2022
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
18 April 2024
Date name of promoter subject to Stop Notice published
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Procorre LLP
Details of persons suspected of promoting the scheme, or of being a connected person
Procorre LLP (Registered in Singapore) / Corre Holdings SA (Registered in Switzerland) / Mr Darren Patrick-Green — also known as Mr Darren Green / Mr Jason Bougourd / Ms Alizeh Nanji
Addresses of persons suspected of promoting the scheme, or of being a connected person
Procorre LLP: 33 Ubi Avenue 3, #08-61, Singapore 408868, Republic of Singapore / Corre Holdings SA: Rue du Rhône 118 Genève, GENÈVE, 1204 Switzerland
Date of publication
29 February 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
It is HMRC’s view that the drawings, pre-paid expense cards and business development fund payments received by users represent the rewards for their services provided to end clients and should therefore be subject to Income Tax and National Insurance contributions. HMRC have previously issued a Spotlight on disguised Renumeration Asset Transfer Arrangements intended to avoid the loan charge. The individuals named are connected persons due to their control over the LLP. Mr Patrick-Green is the Ultimate Beneficial Owner of Corre Holdings SA (CHSA). CHSA is a designated member and majority owner of the LLP. HMRC also suspect that CHSA are involved in moving Users to a further set of arrangements which involve the acquisition of their PSC.
Protean Ltd
Details of persons suspected of promoting the scheme, or of being a connected person
Protean Ltd (PL) / Mr Jonathan Milne (Director of Protean Ltd)
Addresses of persons suspected of promoting the scheme
128 City Road, London, EC1V 2NX
Date of publication
21 November 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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 should be subjected to Income Tax and NICs. Jonathan Milne was identified as a director of Wilson Costello Ltd which was published under Finance Act 2022 on 31 August 2023. HMRC have previously published Spotlight 60 on disguised remuneration schemes involving agency workers and contractors employed by umbrella companies. HMRC are aware that some umbrella companies operate more than one scheme, such as a standard compliant scheme and a non-compliant scheme. HMRC has reason to suspect that PL target social workers in North West England, working in the care sector and for local council authorities. HMRC advise employees of PL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.
Purity Ltd
Details of persons suspected of promoting the scheme, or of being a connected person
Purity Ltd / Rebecca Waterfield (Director of Purity Ltd)
Address of person suspected of promoting the scheme
85 Great Portland Street, London, W1W 7LT
Date of publication
25 January 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Pure Employment Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Pure Employment Limited (Company number 14910155) / Stuart Ian Dutton — also known as Stuart Ian Thomas Dutton (former Director of Pure Employment Limited)
Addresses of persons suspected of promoting the scheme
Pure Employment Limited: 128 City Road, London, United Kingdom, EC1V 2NX
Date of publication
5 June 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Purple Pay Limited
Name of promoter
Purple Pay Limited
Date arrangements subject to Stop Notice published
13 April 2023
Date name of promoter subject to Stop Notice published
We have published 2 entries that relate to a scheme operated by Rainbowpay Ltd:
entry 1 — published under Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
Rainbowpay Ltd / Lyndsey Pauline Scott — (Former Director of Rainbowpay Ltd) / Sunil Lekhi — (Former Director of Rainbowpay Ltd) / Flexen Ltd (Incorporated in Cyprus) / Giannakis Fysentzou (Director of Flexen Ltd and counter signatory to the Annuity Agreements)
Addresses of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation
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
Date of publication
1 December 2023
Publication last updated
13 February 2025
Legislation under which this scheme/promoter has been named
Finance Act 2022
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
12 September 2024
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme
Rainwize Umbrella Limited (RUL)
Addresses of persons suspected of promoting the scheme
307 Cotton Exchange Building, Old Hall Street, Liverpool, L3 9LQ
Date of publication
16 January 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
React Administration Services Limited
Details of persons suspected of promoting the scheme, or of being a connected person
React Administration Services Limited (RASL) / Kevin Taylor (Director of RASL)
Addresses of persons suspected of promoting the scheme
2 Brunel Way, Slough, SL1 1XL
Date of publication
29 February 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Real Payments Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Real Payments Limited (RPL) (Company number 15426462) / Ian Moffitt (Director of RPL)
Addresses of persons suspected of promoting the scheme
RPL: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ
Date of publication
14 August 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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. RPL director, Ian Moffitt, is also the director of Titan Payment Solutions Limited, which was published for operating a disguised remuneration scheme on 28 November 2024. HMRC advise employees of RPL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
Regis Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Regis Limited (RL) (Incorporated in Isle of Man) / Ernest Umbrella Limited (in liquidation) (EUL) (Company number 14104089) / Imagine Umbrella Limited (in liquidation) (IUL) (Company number 14632904) / Thomas Tidy (RL director) / Stephen Tidy (RL director) / Stephen Charles Biggs (EUL Director) / Ross Plowman (IUL Director)
Addresses of persons suspected of promoting the scheme, or of being a connected person
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
Date of publication
14 August 2025
Legislation under which this scheme/promoter has been named
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.
Remuneration Assured Ltd
Details of persons suspected of promoting the scheme
Remuneration Assured Ltd (RAL)
Date of publication
13 February 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Resource Hubco Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Resource Hubco Limited (RHL) / Cornelia Van-Der-Sluis (Director of RHL)
Addresses of promoters suspected of promoting the scheme
3 Piccadilly Place, Manchester, M1 3BN
Date of publication
28 June 2023
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Rosewood WM IO Services Ltd
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
Rosewood WM IO Services Ltd (in liquidation) (RWM)/ Elliott Lee Bushby — former director of Rosewood WM IO Services Ltd / James Grubb — director of Rosewood WM IO Services Ltd / Dynasty Payroll Solutions Ltd
Addresses of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
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
Date of publication
8 August 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
RW Operations Ltd
Details of persons suspected of promoting the scheme
RW Operations Ltd (RWO)
Addresses of persons suspected of promoting the scheme
85 Great Portland Street, London, W1W 7LT
Date of publication
8 August 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Saxonside Limited – Saxonside Option Grant
Name of promoter
Saxonside Limited (SAX)
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
2 March 2023
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme, or of being a connected person
Signature Pay Limited (SPL) / Mr Samuel Joseph Heys (Director of SPL)
Addresses of persons suspected of promoting the scheme
Peter House, Oxford Street, Manchester, M1 5AN
Date of publication
10 October 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Signature Professional Limited
Details of persons suspected of promoting the scheme, or being a connected person
Signature Professional Limited (Company no: 15486244) / Michael David Hance (Director of Signature Professional Limited)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Signature Vintage Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Signature Vintage Limited (SVL)
Address of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
SmartPay Limited
Name of scheme
SmartPay Third Party Loan
Name of promoter or supplier of scheme
SmartPay Limited (Incorporated in the Isle of Man) (SmartPay (IOM)) / SmartPay Limited (Incorporated in the UK) (SmartPay (UK))
Address of promoter or supplier of scheme
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
Date of publication
24 August 2023
Scheme reference number (SRN)
62482307
Date SRN allocated to the scheme
23 June 2022
Legislation under which this scheme/promoter has been named
Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based
Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work — summary
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.
Legislation under which this scheme/promoter has been named
Finance Act 2022
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
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
12 September 2024
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme, or of being a connected person
Stark Payment Services Ltd (SPSL) (in liquidation) / Martin Andrew Jones (Director of SPSL) / Carl James Woods (former director of SPSL)
Addresses of persons suspected of promoting the scheme
Former address: Unity Building, 20 Chapel Street, Liverpool, L3 9AG
Date of publication
16 January 2025
Last updated
24 July 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Summit LED Ltd
Details of persons suspected of promoting the scheme, or of being a connected person
Summit LED Ltd (SLL) trading as Adept Pay / Sayf Aashik (former director of SLL)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Titan Payment Solutions Limited
Details of persons suspected of promoting the scheme
Titan Payment Solutions Limited (TPS)
Addresses of persons suspected of promoting the scheme
196 High Road, Wood Green, London, N22 8HH
Date of publication
28 November 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Trident Umbrella Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Trident Umbrella Limited / Michael Paul Griffin (Director of Trident Umbrella Limited)
Addresses of persons suspected of promoting the scheme
Two Four Nine North, Lynnfield House, Church Street, Altrincham, England, WA14 4DZ
Date of publication
13 February 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
T.U Pay Limited
Details of persons suspected of promoting the scheme
T.U Pay Limited (TUPL) (Company number SC806609)
Addresses of persons suspected of promoting the scheme
272 Bath Street, Glasgow, Scotland, G2 4JR
Date of publication
31 July 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
365 Umbrella Ltd
Details of persons suspected of promoting the scheme
365 Umbrella Ltd
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Ultra Employment Ltd
We have published 2 entries relating to schemes operated by Ultra Employment Ltd:
entry 1 — published under the Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Details of persons suspected of promoting the scheme, or of being a connected person
Ultra Employment Ltd (UEL) / Mr Barry Aldridge (Director of UEL)
Date of publication
11 April 2024
Legislation under which this scheme/promoter has been named
Finance Act 2022
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
6 February 2025
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme, or of being a connected person
The Umbrella Agency Limited (TUA) / Stuart John Brooke (director of The Umbrella Agency Limited) / Griffith Anderson Limited/Setu Kamal (Barrister)
Addresses of promoters suspected of promoting the scheme
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
Date of publication
31 August 2022
Last updated
4 September 2025
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
The scheme reference number 05565111 was allocated to the arrangements on 3 August 2022. The employing company, TUA, states that it simply acts as a payroll bureau and agent for another company based in Malta under the ultimate direction of the same director as the employing company. 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. HMRC suspects Setu Kamal is responsible for the design of the scheme arrangements and has created and supplied contract and agreement templates which are integral to the implementation of the relevant arrangements.
Umbrella Contracts Limited
Details of persons suspected of promoting the scheme
Umbrella Contracts Limited (UCL) (Company number SC192044) — in administration / Fairview Administration Services Ltd (FASL) (Company number 10359717) / Momentum Corporate Services Limited (Seychelles) (MCSL)
Addresses of persons suspected of promoting the scheme
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
Date of publication
31 July 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Umbrella Link Ltd
Details of persons suspected of promoting the scheme
Umbrella Link Ltd (ULL)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Umbrella Union Ltd
Details of persons suspected of promoting the scheme
Umbrella Union Ltd (UUL)
Addresses of promoters suspected of promoting the scheme
9 Burns Street, Bootle L20 4RJ
Date of publication
10 October 2024
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Umbrella Zone Limited
Details of persons suspected of promoting the scheme, or of being a connected person
Umbrella Zone Limited (UZL) / Ian Falconer (Director of UZL)
Addresses of persons suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
United Pension Administration Ltd
Name of scheme
NHMA Pension Benefits Scheme
Details of persons suspected of promoting the scheme
United Pension Administration Ltd (UPA) / Countryside Capital Ltd (CCL)
Addresses of persons suspected of promoting the scheme
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
Date of publication
19 September 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Universe Payroll Limited
We have published 2 entries that relate to a scheme operated by Universe Payroll Limited:
entry 1 — published under Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation
Addresses of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation
UPL: 7 Bell Yard, London, WC2A 2JR / Bonzai Umbrella Limited: 7 Bell Yard, London, WC2A 2JR
Date of publication
13 March 2025
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Name of promoter
Universe Payroll Limited
Date arrangements subject to Stop Notice published
17 October 2024
Date name of promoter subject to Stop Notice published
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
HMRC have previously published information about The Umbrella Agency Ltd, for which Stuart John Brooke is also a director. HMRC has published Spotlight 35 in 2017 on disguised remuneration schemes involving annuity agreements, based on a predecessor arrangement. 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. HMRC suspects Setu Kamal is responsible for the design of the scheme arrangements and has created and supplied contract and agreement templates which are integral to the implementation of the relevant arrangements.
Vision HR Solutions Ltd
Name of scheme
Vision HR Remuneration Structure
Details of persons suspected of promoting the scheme, or of being a connected person
Vision HR Solutions Ltd (Incorporated in Malta) — Offshore Promoter / Stuart John Brooke (Director of Vision HR Solutions Ltd (Malta)) / Vision Human Resource Solution Ltd — UK Promoter/Setu Kamal (Barrister)
Addresses of promoters suspected of promoting the scheme
Legislation under which this scheme/promoter has been named
Finance Act 2022
How the scheme is claimed to work — summary
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.
Any other information HMRC considers relevant to publish about these schemes
HMRC have previously published information about The Umbrella Agency Ltd, for which Stuart John Brooke is also a director. HMRC has published Spotlight 35 in 2017 on disguised remuneration schemes involving annuity agreements, based on a predecessor arrangement. HMRC suspects Setu Kamal is responsible for the design of the scheme arrangements and has created and supplied contract and agreement templates which are integral to the implementation of the relevant arrangements.
Vision Human Resource Solutions Ltd
Name of promoter
Vision Human Resource Solutions Ltd (VHR UK)
Date arrangements subject to Stop Notice published
6 February 2025
Date name of promoter subject to Stop Notice published
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
We Are Ava Limited
Details of persons suspected of promoting the scheme
We Are Ava Limited (WAA) (formerly Hunter State Limited)
Address of persons suspected of promoting the scheme
61 Mosley Street, Manchester, M2 3HZ
Date of publication
16 May 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Whitebridge Management Ltd
We have published 2 entries that relate to one scheme operated by Whitebridge Management Ltd:
entry 1 — published under the Finance Act 2022
entry 2 — published under Promoters of Tax Avoidance Schemes regime
Scheme entry
1
Details of persons suspected of promoting the scheme
Whitebridge Management Ltd (WML)
Addresses of persons suspected of promoting the scheme
71-75 Shelton Street, London, England, WC2H 9JQ
Date of publication
8 August 2024
Legislation under which this scheme/promoter has been named
Finance Act 2022
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.
Any other information HMRC considers relevant to publish about these schemes
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.
Scheme entry
2
Legislation under which this Stop Notice has been published
Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published
6 February 2025
Date name of promoter subject to Stop Notice published
Details of persons suspected of promoting the scheme, or of being a connected person
Your Pay Ltd (YPL) / Ronnie Welsh (sole director of YPL)
Addresses of promoters suspected of promoting the scheme
71-75 Shelton Street, London, WC2H 9JQ
Date of publication
22 August 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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 45Spotlight 60 based on similar arrangements.
Your PAYE Limited
Details of persons suspected of promoting the scheme
Your PAYE Limited
Addresses of persons suspected of promoting the scheme
Former address: 167-169 Great Portland Street, London, W1W 5PF / Current address: Floor 2, 10 Wellington Place, Leeds, LS1 4AP
Date of publication
8 August 2024
Legislation under which this scheme/promoter has been named
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.
Any other information HMRC considers relevant to publish about these schemes
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.
