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* HM Revenue & Customs Corporate report CURRENT LIST OF NAMED TAX AVOIDANCE SCHEMES, PROMOTERS, ENABLERS AND SUPPLIERS Updated 5 June 2025 CONTENTS * 1. How to use the information on

this page * 2. Most recently named promoters * 3. List of named tax avoidance schemes, promoters, enablers and suppliers * 3. If you’re involved in a tax avoidance scheme * 4. Details of how

each named scheme is claimed to work * 5. Explanation of terms used Print this page © Crown copyright 2025 This publication is licensed under the terms of the Open Government Licence v3.0

except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew,

London TW9 4DU, or email: [email protected]. Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.

This publication is available at

https://www.gov.uk/government/publications/named-tax-avoidance-schemes-promoters-enablers-and-suppliers/current-list-of-named-tax-avoidance-schemes-promoters-enablers-and-suppliers 1. HOW TO

USE THE INFORMATION ON THIS PAGE If you are involved in any of the tax avoidance schemes shown on this page, or recognise any of the promoters, enablers or suppliers, you should contact

HMRC as soon as possible. There is more information about how to do this below. You can also report a tax avoidance scheme to HMRC. There are other schemes, promoters, enablers and suppliers

that HMRC cannot publish information about at this time. This may be because: * HMRC is gathering information about the promoter, enabler, supplier or avoidance schemes being marketed *

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

promoter, enabler or supplier Read more information about what HMRC can publish, and why. If you want to get more information about a company or its directors, you can check Companies House.

You can also check the list of tax avoidance schemes subject to a Stop Notice. 2. MOST RECENTLY NAMED PROMOTERS The most recent additions and updates to the list of named tax avoidance

schemes, promoters, enablers and suppliers in section 3 below were published on 5 June 2025. Additions: * Pure Employment Limited * Arrow Tree Consulting Limited 3. LIST OF NAMED TAX

AVOIDANCE SCHEMES, PROMOTERS, ENABLERS AND SUPPLIERS This list is presented in alphabetical order and is updated regularly. If you recognise any name on this list and are concerned you’re

involved in a tax avoidance scheme, please contact HMRC. A to C D to F G to I J to L M to O P to R S to U V to X Y to Z This is not a complete list of all tax avoidance schemes currently

being marketed. Neither is it a complete list of all promoters, enablers and suppliers. If a tax avoidance scheme is not shown in the list, this does not mean that the scheme works or is in

any way approved by HMRC. HMRC does not approve tax avoidance schemes for use. A TO C * ABC Umbrella Ltd * Abchurch LTD * Acacia Management Services Limited * Accent Umbrella Ltd * Acquda

Limited * Acquda Solutions Limited * Adapt Limited (Based in Isle of Man) * Adept Pay – see Summit LED Ltd * ADYE Ltd (Based in Cyprus) – see Apricot Umbrella Limited * Agile Pay Ltd * AI

Global Workforce Ltd * Alphasaint Ltd * AML Tax (UK) Limited * Apricot Umbrella Limited * Arrow Tree Consulting Limited * Astra Limited * B2BTradecard Ltd * Back Office Assistance 1 Limited

* Back Office Services 1 Limited * Back Office Systems 1 Limited * Balance Bay Limited * Balance Bay Services Limited * Bestia Holdings Ltd (Incorporated in Cyprus) – see Dalespay Ltd * BHD 

Consultants Ltd – see Miwsa Limited * Blizzard Pay Ltd * Bluemoore Associates Ltd * Bluestar Financial Solutions Limited * Bonzai Umbrella Limited – see Universe Payroll Limited * The

Brightest Future Limited * Buckingham Wealth Ltd (Incorporated in Belize) * Burnsall Pay Ltd * Calculate Limited * Canopaye Limited * Century Umbrella Limited * Charteris Management Ltd *

Clear Water Administration Limited * Compas Limited (incorporated in the Isle of Man) * Compliant Pay Ltd * Connection Point Ltd * Consortius Solutions Limited * Contractor Buddy PCC Limited

(Incorporated in Isle of Man) – see Payeworx Ltd * Contractor Bureau Limited * Contractor Corner Accounting Limited – see Optima Limited * Contractorcare Ltd * Corre Holdings SA (Registered

in Switzerland) – see Procorre LLP * Cotswold Barristers Ltd – see Property118 Ltd * Countryside Capital Ltd – see United Pension Administration Ltd * Countrywide Partners Limited * Cube

Umbrella Limited This is part of the alphabetical list of named tax avoidance schemes, promoters, enablers and suppliers. D TO F * Dalespay Ltd * Denmedical UK Limited – see AML Tax (UK)

Limited * Deposlo Holdings Ltd (based in Cyprus) – see Edge Umbrella Limited * Dynasty Payroll Solutions Ltd – see Greenlight Payroll Services Limited and Rosewood WM IO Services Ltd *

Earneze Limited * Easyway Umbrella Limited * Edge Umbrella Limited * Employe Limited * Employe US Limited * Ernest Umbrella Limited – see Compas Limited (incorporated in the Isle of Man) *

Everest Contracting Limited * Excala Solutions Limited * Expertise Solutions Limited * Fast Payroll UK Ltd * Fastpay - see Fast Payroll UK Ltd * 1st Choice Umbrella Ltd * First Paye

Consultants Limited * Flex Payroll and Accounting Services Ltd * Flexen Ltd (Incorporated in Cyprus) – see Rainbowpay Ltd * Focus Contractor Limited * Frank Umbrella Limited – See Adapt

Limited and Optima Limited This is part of the alphabetical list of named tax avoidance schemes, promoters, enablers and suppliers. G TO I * GL Platinum Ltd * GL Premium Ltd * Goldfish

Umbrella Limited * Greenlight Payroll Operations Ltd – See Greenlight Payroll Services Limited * Greenlight Payroll Services Limited * Griffith Anderson Limited – see Charteris Management

Ltd and The Umbrella Agency Limited * Hamilton Bradbury Ltd * Hive Umbrella Ltd * Howe Consultancy Limited (Incorporated in Isle of Man) – see Charteris Management Ltd * HRG Consulting Ltd –

see Miwsa Limited * HWX Consulting Ltd – see Miwsa Limited * Imace Limited * Imagine Umbrella Limited – see Compas Limited (incorporated in the Isle of Man) * Infrapro Consulting Limited *

Integra Resourcing Limited (Incorporated in Malta) – see Charteris Management Ltd * Innovate Limited (Registered in the Isle of Man) * Intu Solutions Limited * IP Global Consulting Ltd This

is part of the alphabetical list of named tax avoidance schemes, promoters, enablers and suppliers. J TO L * JBatts Ltd – see Miwsa Limited * Jeceris Limited – see Charteris Management Ltd *

Jigsaw Pay - see Jigsaw Payment Solutions Limited * Jigsaw Payment Solutions Limited * JJDM Consulting Ltd – see Miwsa Limited * Just Standard Limited * K & B Umbrella Ltd * Knight

& Bishop – see K & B Umbrella Ltd * Knight and Bishop Services – see K & B Umbrella Ltd * Krevit Ltd – see ABC Umbrella Ltd * Langan Scott and Co Ltd * Level Up Associates

Limited * LWI Services Limited (Address in British Virgin Islands) This is part of the alphabetical list of named tax avoidance schemes, promoters, enablers and suppliers. M TO O *

Masterstroke Solutions Limited * Medbridge Ltd * Minerva Services Ltd (formerly incorporated in Belize) – see Buckingham Wealth Ltd * Miwsa Limited * Miwsa Management Ltd   * MLG Pay Limited

* Mountain View Admin Limited * Mountain View Administration Limited – see Mountain View Admin Limited * New Mill Resourcing Ltd * NM Recruitment Services Ltd * Odyssey Payroll Limited *

Olympus Contracting Limited * Ombros Solutions Limited – see Charteris Management Ltd * Omni Contractors PCC Limited (Incorporated in Isle of Man) – see Pinnacle and Partners Limited,

Saxonside Limited and 1st Choice Umbrella Ltd * On the Box Pay Ltd * Optima Limited (Registered in the Isle of Man) * Saxonside Share Growth This is part of the alphabetical list of named

tax avoidance schemes, promoters, enablers and suppliers. P TO R * Paul Baxendale-Walker * PAYE Services Limited * PAYEme Ltd * Payeworx Ltd * Pay Rec Limited * Payroll Professors Limited *

Paystone Services Limited * Pazepay Limited * Peak PAYE Limited * Penhale Solutions Limited * Pinnacle and Partners Limited * Prime Umbrella Services Ltd * PRC Recruitment Ltd * Procorre LLP

(Registered in Singapore) * Property118 Ltd * Protean Ltd * Purity Ltd * Pure Employment Limited * Purple Pay Limited * Rainbowpay Ltd * Rainwize Umbrella Limited * React Administration

Services Limited * Remuneration Assured Ltd * Resource Hubco Limited * Rosewood WM IO Services Ltd * RW Operations Ltd This is part of the alphabetical list of named tax avoidance schemes,

promoters, enablers and suppliers. S TO U * Saxonside Limited * Saxonside Share Growth * Signature Pay Limited * Signature Vintage Limited * SmartPay Limited (Incorporated in the Isle of

Man) * Solucionis Limited * Stark Payment Services Ltd * Succeed in Property Ltd – see Property118 Ltd * Summit LED Ltd * Target Umbrella Limited – see Integra Resourcing Limited * Taurus

Limited (Incorporated in Isle of Man) – see Charteris Management Ltd * TGI Payday Ltd – See Adapt Limited and Astra Limited * Titan Payment Solutions Limited * Trident Umbrella Limited * 365

Umbrella Ltd * Ultimate Planning Ltd – see Compliant Pay Ltd * Ultra Employment Ltd * The Umbrella Agency Limited * Umbrella Link Ltd * Umbrella Union Ltd * Umbrella Zone Limited * United

Pension Administration Ltd * Universe Payroll Limited This is part of the alphabetical list of named tax avoidance schemes, promoters, enablers and suppliers. V TO X * Veqta Ltd * Vision HR

Solutions Ltd * Vision Human Resource Solutions Ltd * Vortexx Limited  * We Are Ava Limited * Whitebridge Management Ltd * Wilson Costello Limited – see Prime Umbrella Services Ltd Y TO Z *

Your Pay Ltd * Your PAYE Limited This is part of the alphabetical list of named tax avoidance schemes, promoters, enablers and suppliers. ABC UMBRELLA LTD DETAILS OF PERSONS 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, 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 Adapt Limited, 6th Floor, Harbour Court, Lord Street, Douglas, Isle of Man, IM1 4LN / Frank Umbrella Limited, C/O Cg & Co, 27 Byrom Street, Manchester, M3 4PF / TGI Payday

Limited, 145 Grimsby Road, Cleethorpes, England, DN35 7DG 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 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 17 October 2024 POTAS PUBLICATION List of tax avoidance

schemes subject to a stop notice AI GLOBAL WORKFORCE LTD NAME OF PROMOTER AI Global Workforce Ltd DATE ARRANGEMENTS SUBJECT TO STOP NOTICE PUBLISHED 12 September 2024 DATE NAME OF PROMOTER

SUBJECT TO STOP NOTICE PUBLISHED 12 September 2024 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice 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. JUDICIAL RULINGS RELATING TO THE SCHEME HMRC v AML Tax (UK) Ltd [2022] UKFTT 114 AML TAX (UK) LIMITED – AML

PREFUNDED EBT NAME OF SCHEME AML Prefunded EBT 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) 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. JUDICIAL RULINGS RELATING TO THE SCHEME HMRC v AML Tax

(UK) Ltd [2022] UKFTT 114 AML TAX (UK) LIMITED – AML SPLIT CONTRACT NAME OF SCHEME AML Split Contract NAME OF PROMOTERS OR SUPPLIERS OF SCHEME 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. JUDICIAL RULINGS RELATING TO THE SCHEME HMRC v AML Tax (UK) Ltd and Denmedical UK Ltd [2022] UKFTT 174 APRICOT UMBRELLA LIMITED 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 Apricot Umbrella Limited: 20 North Lane, Canterbury, CT2 7PG / ADYE Ltd: 5-7 G&S Court, 4th Floor, Flat/Office

401, 6030, Larnaca, Cyprus 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 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, 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 Astra Limited: 6th Floor, Harbour Court, Lord Street, Douglas, Isle of Man, IM1 4LN / TGI Payday Limited: 145 Grimsby Road, Cleethorpes, England, DN35 7DG 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 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 LTD DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Promoter: B2BTradecard Ltd (B2B)

ADDRESSES OF PERSONS SUSPECTED OF PROMOTING THE SCHEME 5a Chorley Business and Technology Centre, Euxton Lane, Chorley, PR7 6TE 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 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. 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. 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) ADDRESSES OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Office 5272, 321-323 High Road, Romford, England, 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 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. 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 Bluemoore

Associates Ltd: 50 Princes Street, Ipswich, IP1 1RJ DATE OF PUBLICATION 28 June 2023 PUBLICATION LAST UPDATED 1 December 2023 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, 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 Bluestar Financial Solutions Limited, 71-75 Shelton Street, London, WC2H 9JQ DATE OF PUBLICATION 17 November 2023

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 10 November

2023 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice BURNSALL PAY LTD DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Burnsall Pay Ltd (BURN) ADDRESSES OF

PERSONS SUSPECTED OF PROMOTING THE SCHEME 26 Bromwich House, 45 Howson Terrace, Richmond Hill, Richmond, TW10 6RU 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 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 Dept 3671, 601 International

House, 223 Regent Street, London, W1B 2QD 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 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 1. Charteris Management Ltd (CML) / 2. Taurus Limited (Incorporated Isle of Man) / 3. Howe Consultancy

Limited (Incorporated Isle of Man) / 4. Griffith Anderson Limited / 5. Integra Resourcing Ltd (Incorporated Malta) / 6. Jeceris Limited / 7. Ombros Solutions Limited 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. 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 8 May 2025 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice CONTRACTORCARE LTD NAME OF PROMOTER Contractorcare Ltd DATE ARRANGEMENTS SUBJECT TO STOP

NOTICE PUBLISHED 2 March 2023 DATE NAME OF PROMOTER SUBJECT TO STOP NOTICE PUBLISHED 18 April 2024 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice COUNTRYWIDE

PARTNERS LIMITED 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 Dalespay Ltd: 17 Olav Road,

Richmond, England, DL10 4PU / Bestia Holdings Ltd: 5-7 G&S Court, 4th Floor, Flat/Office 401 6030, Larnaca, Cyprus DATE OF PUBLICATION 18 August 2023 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 Earneze Limited, 20-22 Wenlock Road, London, England, N1 7GU 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 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 Innovation House, 39 Mark Road, Hemel Hempstead

Industrial Estate, Hemel Hempstead, HP2 7DN DATE OF PUBLICATION 27 July 2023 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 Edge Umbrella Limited, 78 York Street, London, W1H 1DP / Deposlo Holdings Ltd,

15 Linda Court, Floor 3, 6051, Lanaka, Cyprus DATE OF PUBLICATION 25 September 2023 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 Current address: Floor 2, 10

Wellington Place, Leeds, LS1 4AP / Previous address: 50 Princes Street, Ipswich, IP1 1RJ 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 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. 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. EXCALA

SOLUTIONS LIMITED DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Excala Solutions Limited (ESL) ADDRESS OF PROMOTERS SUSPECTED OF PROMOTING THE SCHEME Excala Solutions Limited, 71-75

Shelton Street, Greater London, WC2H 9JQ DATE OF PUBLICATION 17 November 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 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 (Former address) 71-75 Shelton Street, Covent Garden, London,

WC2H 9JQ 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 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 12 September 2024 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice FIRST PAYE CONSULTANTS LIMITED 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 6 March 2025 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice FOCUS CONTRACTOR

LIMITED NAME OF PROMOTER Focus Contractor Limited LEGISLATION UNDER WHICH THIS STOP NOTICE HAS BEEN PUBLISHED Promoters of Tax Avoidance Schemes (POTAS) DATE ARRANGEMENTS SUBJECT TO STOP

NOTICE PUBLISHED 13 April 2023 DATE PUBLICATION WAS LAST UPDATED 7 June 2023 DATE NAME OF PROMOTER SUBJECT TO STOP NOTICE PUBLISHED 12 October 2023 POTAS PUBLICATION List of tax avoidance

schemes subject to a stop notice 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 7 Bell Yard, London, WC2A 2JR / 117 Ellingham Way, Ashford, TN23 6LZ 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 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 14 November 2024 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice GREENLIGHT PAYROLL SERVICES LIMITED 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/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. JUDICIAL RULINGS RELATING TO THE SCHEME  HMRC v

Hamilton Bradbury Limited (in liquidation) UKFTT 99 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 10 November 2023 POTAS 

PUBLICATION List of tax avoidance schemes subject to a stop notice IMACE LIMITED DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME, OR OF BEING A CONNECTED PERSON Imace Limited ADDRESSES

OF PERSONS SUSPECTED OF PROMOTING THE SCHEME 58 Office 565, 58 Peregrine Road, Hainault, Ilford, Essex, IG6 3SZ DATE OF PUBLICATION 20 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 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 LIMITED DETAILS OF PERSONS

SUSPECTED OF PROMOTING THE SCHEME Infrapro Consulting Limited (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 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 have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies. HMRC is aware

that some umbrella Companies operate more than one scheme, for example, a standard compliant scheme and a non-compliant scheme. HMRC advises employees of ICL to familiarise themselves with

the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. 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 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ 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 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.  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. 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 17 October 2024 POTAS 

publication List of tax avoidance schemes subject to a stop notice MASTERSTROKE SOLUTIONS LIMITED 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 DATE STOP NOTICE ISSUED 15 May 2024 DATE OF PUBLICATION 15 May 2025 POTAS PUBLICATION List

of tax avoidance schemes subject to a stop notice MIWSA LIMITED DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME, OR HAVING ANY OTHER ROLE IN RELATION TO MAKING THE SCHEME AVAILABLE FOR

IMPLEMENTATION Miwsa Limited / BHD Consultants Ltd (BHD) / HRG Consulting Ltd (HRG) / HWX Consulting Ltd (HWX) / JBatts Ltd (JBL) / JJDM Consulting Ltd (JJDM) ADDRESSES OF PERSONS SUSPECTED

OF PROMOTING THE SCHEME, OR HAVING ANY OTHER ROLE IN RELATION TO MAKING THE SCHEME AVAILABLE FOR IMPLEMENTATION Miwsa Limited: Suite 03, 5 Wandsworth Road, Perivale, London, UB6 7JD / BHD

Consultants Ltd: 28 Newcombe Court, Burgess Springs, Chelmsford, Essex CM1 1QN / HRG Consulting Ltd: 30 Jameston, Bracknell, RG12 7WZ / HWX Consulting Ltd: 14 Ravensbury Avenue, Morden, SM4

6ET / JBatts Ltd: 14 Ravensbury Avenue, Morden, SM4 6ET / JJDM Consulting Ltd: 20-22 Wenlock Road, London, N1 7GU DATE OF PUBLICATION 19 September 2024 INFORMATION UPDATED 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 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) ADDRESSES OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Suite 101, 89 High Street, Sidcup, DA14 6DW DATE OF PUBLICATION 21

December 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 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. 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 6 February 2025 POTAS publication List of tax avoidance schemes subject to a stop notice 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 Mountain View Admin Limited, 71-75 Shelton Street, Covent Garden, London. WC2H 9JQ

(registered office) / Mountain View Administration Limited, Gatcombe House, Copnor Road, Portsmouth, Hampshire, PO3 5EJ (registered office) 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 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 Olympus Contracting Limited,

63-66 Hatton Garden, London, EC1N 8LE DATE OF PUBLICATION 25 September 2023 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 21 March 2024 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice ON THE BOX PAY LTD 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 15

May 2025 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice STOP NOTICE ENTRY 2 DATE ARRANGEMENTS SUBJECT TO STOP NOTICE PUBLISHED 15 May 2025 DATE NAME OF PROMOTER

SUBJECT TO STOP NOTICE PUBLISHED 15 May 2025 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice PAYE SERVICES LIMITED We have published 2 entries that relate to this

scheme operated by PAYE Services Ltd: * entry 1 – published under the Finance Act 2022 * entry 2 – published under Promoters of Tax Avoidance Schemes regime 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 10 November 2023 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice PAYEME LTD NAME OF PROMOTER PAYEme Ltd

DATE ARRANGEMENTS SUBJECT TO STOP NOTICE PUBLISHED 2 March 2023 DATE NAME OF PROMOTER SUBJECT TO STOP NOTICE PUBLISHED 18 April 2024 POTAS PUBLICATION List of tax avoidance schemes subject

to a stop notice PAYEWORX LTD DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Payeworx Ltd (PWL) / Contractor Buddy PCC Limited (CBP) (Incorporated in Isle of Man) ADDRESSES OF

PROMOTERS SUSPECTED OF PROMOTING THE SCHEME Payeworx Ltd, Newspaper House, Tannery Lane, Penketh, Warrington, Cheshire, WA5 2UD / Contractor Buddy PCC Limited, 2nd Floor, Murdoch Chambers,

South Quay, Douglas, Isle of Man, IM1 5AS DATE OF PUBLICATION 24 August 2023 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 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 Payroll Professors

Limited (Company Registration Number: 15492817) 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 7 June 2023 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice PENHALE SOLUTIONS LIMITED 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 18 April 2024 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice PRC RECRUITMENT LTD DETAILS OF PERSONS SUSPECTED OF PROMOTING

THE SCHEME PRC Recruitment Ltd (PRC) (Company Registration Number: 14106838) 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 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. PROPERTY118 LTD We have published entries that relate to 2 schemes operated by Property 118 Ltd: * scheme 1 – published under

Disclosure of Tax Avoidance Schemes (DOTAS) * scheme 2 – published under Disclosure of Tax Avoidance Schemes (DOTAS) SCHEME ENTRY 1 NAME OF SCHEME  Substantial Incorporation Structure NAME

OF PROMOTER OR SUPPLIER OF SCHEME Property118 Ltd (P118) / Cotswold Barristers Ltd (CBL) ADDRESS OF PROMOTER OR SUPPLIER OF SCHEME P118: 1st Floor Woburn House, 84 St. Benedicts Street,

Norwich, Norfolk, NR2 4AB / CBL: D5 Cotswold Airport, Kemble, Gloucestershire, England, GL7 6BA DATE OF PUBLICATION 19 September 2024 SCHEME REFERENCE NUMBER (SRN) 53560969 DATE SRN

ALLOCATED TO THE SCHEME  9 February 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  Section 162 Taxation of Capital Gains Act 1992 HOW THE SCHEME IS CLAIMED TO WORK Users enter into a ‘Sale and Purchase Agreement’ to sell their property business to a

company wholly in exchange for shares. They also enter a Trust Deed, Agency Agreement and Contract for Sale. The trust holds the legal interest in the properties and the Contract for Sale

allows for a delay on the transfer of legal titles. The mortgage liabilities are not actually transferred or repaid. Instead, the company adopts responsibility for the liabilities in the

form of an indemnity. Users are appointed as agents of the company to make and receive payments, including mortgage payments for the properties. Once the transfer has taken place, the

company holds the beneficial interests in the properties. It also, as per the indemnity, reimburses the user for the mortgage payments the user makes, and claims interest relief against its

profits. It is claimed that there is no capital gains tax on the sale due to rollover relief for transfer of business assets. SCHEME ENTRY 2 NAME OF SCHEME Capital Account Restructure NAME

OF PROMOTER OR SUPPLIER OF SCHEME Property118 Ltd (P118) / Cotswold Barristers Ltd (CBL) / Succeed in Property Ltd (SIPL) ADDRESS OF PROMOTER OR SUPPLIER OF SCHEME  P118: 1st Floor Woburn

House, 84 St. Benedicts Street, Norwich, Norfolk, NR2 4AB / CBL: D5 Cotswold Airport, Kemble, Gloucestershire, England, GL7 6BA / SIPL: 2nd Floor (Rear Suite), 54-56 Victoria Street, St

Albans, AL1 3HZ DATE OF PUBLICATION 19 September 2024 SCHEME REFERENCE NUMBER (SRN) 07626525 DATE SRN ALLOCATED TO THE SCHEME 9 February 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 Section 162 Taxation of Capital Gains Act 1992 HOW THE SCHEME IS CLAIMED TO

WORK Scheme users, a company they manage, and a lender enter a ‘facility agreement’ for a bridging loan.  Users then enter an agreement to sell their property business to their company in

exchange for shares. A trust holds the legal interest in the properties and a Contract for Sale is used to delay the transfer of legal title. The business’ liabilities are not actually

repaid; the company adopts responsibility for them in the form of an indemnity. Users are appointed agents of their company to handle its payments. Users draw down the bridging loan prior to

the sale completion; however, the company will become responsible for the loan post transfer and will not have funds to repay the loan. After the transfer, the users loan the company the

required amount to repay the bridging loan. The users’ director’s loan account is credited with the loaned amount, which they expect to draw from tax free. It is claimed that no capital

gains tax is due on the sale due to rollover relief for transfer of business assets. 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 7 December 2023 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice

RAINBOWPAY LTD We have published 2 entries that relate to a scheme operated by Rainbowpay Ltd: * entry 1 – published under Finance Act 2022 * entry 2 – published under Promoters of Tax

Avoidance Schemes regime SCHEME ENTRY 1 DETAILS OF PERSONS 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 6 March 2025 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice RAINWIZE UMBRELLA LIMITED 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. 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 We have published 2 entries that relate to schemes operated by Saxonside Limited: * entry 1:

Saxonside Option Grant – published under Promoters of Tax Avoidance regime * entry 2: Saxonside Share Growth – published under Finance Act 2022 SAXONSIDE LIMITED – SAXONSIDE OPTION GRANT

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     7 June 2023 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice SAXONSIDE LIMITED –

SAXONSIDE SHARE GROWTH NAME OF SCHEME Saxonside Share Growth DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME, OR OF BEING A CONNECTED PERSON Saxonside Limited (SAX), Omni Contractors

PCC Limited (OCP), Adam Fathers (director of SAX), Kirsty LeMarechal (former director of OCP) ADDRESSES OF PROMOTERS SUSPECTED OF PROMOTING THE SCHEME Saxonside Limited: Centaur House,

Ancells Road, Fleet GU51 2UJ / Omni Contractors PCC Limited: Unit 2 Close Beg, Peel, Isle of Man IM5 1XF DATE OF PUBLICATION 31 August 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 SAX and receive a share in OCP, a separate, protected cell

company. The share is unique to the scheme user’s name. SAX pay the scheme user a National Minimum Wage (NMW) salary through the payroll and OCP makes an additional payment that is allegedly

for the growth in the share’s value. This is paid without Income Tax and National Insurance contributions (NICs) deductions. SAX alleges that the payment will later be subject to capital

gains tax (CGT), and they retain an amount that they will allegedly release back to scheme users to cover any future CGT liability. Scheme users retain around 71 to 73% of the expected gross

contract value. Read more detail about how this scheme operates. SIGNATURE PAY LIMITED 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 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 71-75 Shelton Street, London, Greater London, WC2H 9JQ 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 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. JUDICIAL RULINGS

RELATING TO THE SCHEME  HMRC v SmartPay Ltd [2022] UKFTT 146 SOLUCIONIS LIMITED We have published 2 entries that relate to this scheme operated by Solucionis Limited: * entry 1 – published

under the Finance Act 2022 * entry 2 – published under Promoters of Tax Avoidance Schemes regime SCHEME ENTRY 1 DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Solucionis Limited

(Solucionis) ADDRESSES OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Horton House, Exchange Flags, Liverpool, England, L2 3PF DATE OF PUBLICATION 25 April 2024 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 12 September 2024 POTAS

 PUBLICATION List of tax avoidance schemes subject to a stop notice STARK PAYMENT SERVICES LTD 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) ADDRESSES OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Former address: Unity Building, 20 Chapel Street,

Liverpool, L3 9AG 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 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 Level One, Basecamp Liverpool, 49 Jamaica Street, Liverpool, Merseyside, England, L1 OAH 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 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. 365 UMBRELLA LTD DETAILS

OF PERSONS SUSPECTED OF PROMOTING THE SCHEME 365 Umbrella Ltd ADDRESSES OF PERSONS SUSPECTED OF PROMOTING THE SCHEME 7 Jardine House, Bessborough Road, Harrow, HA1 3EX 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 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 6 February 2025 POTAS PUBLICATION List of tax avoidance schemes subject to a stop notice THE UMBRELLA AGENCY LIMITED NAME OF SCHEME The

Umbrella Agency Annuity Option Scheme DETAILS OF PERSONS 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 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 22 May 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. UMBRELLA LINK LTD DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Umbrella

Link Ltd (ULL) ADDRESSES OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Lonsdale Gate, Lonsdale Gardens, Tunbridge Wells, TN1 1NU DATE OF PUBLICATION 13 February 2025 LAST UPDATED 22 May 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 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 Gainsborough House, 59-60 Thames Street, Windsor, SL4 1TX 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 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 Universe Payroll Limited (UPL) / Brett Hardiman

(Director of UPL) / Bonzai Umbrella Limited 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 6 February 2025 POTAS PUBLICATION List of tax avoidance

schemes subject to a stop notice VEQTA LTD NAME OF SCHEME Veqta Remuneration Structure DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME, OR OF BEING A CONNECTED PERSON Veqta Ltd

(Incorporated in Malta) – Offshore Promoter / Stuart John Brooke (Director of Veqta Ltd (Malta)) / Veqta Ltd (UK) – Onshore Intermediary ADDRESSES OF PROMOTERS SUSPECTED OF PROMOTING THE

SCHEME Veqta Ltd (Malta), 1, Floor 2, Falzun Street, C/W Naxxar Road, Birkirkara, BKR1441, Malta / Veqta Ltd (UK), 20-22 Wenlock Road, London, N1 7GU DATE OF PUBLICATION 5 July 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 – 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. 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 ADDRESSES OF PROMOTERS SUSPECTED OF PROMOTING THE

SCHEME Vision HR Solutions Ltd (Malta), 1, Floor 2, Falzun Street, C/W Naxxar Road, Birkirkara, BKR1441, Malta / Vision Human Resource Solutions Ltd, 71-75 Shelton Street, London, Greater

London, WC2H 9JQ DATE OF PUBLICATION 5 July 2023 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. 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 6 February 2025 POTAS PUBLICATION

List of tax avoidance schemes subject to a stop notice VORTEXX LIMITED DETAILS OF PERSONS SUSPECTED OF PROMOTING THE SCHEME Vortexx Limited (Company number 15191526) ADDRESSES OF PERSONS

SUSPECTED OF PROMOTING THE SCHEME Office One, 1 Coldbath Square, London, England, EC1R 5HL 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 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 6 February 2025 POTAS PUBLICATION List of tax

avoidance schemes subject to a stop notice YOUR PAY LTD 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 45 Spotlight 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. 3. IF YOU’RE INVOLVED IN A TAX AVOIDANCE SCHEME If you’re worried about becoming involved in a tax

avoidance scheme, or think you’re already involved and want to get out of one, HMRC is here to help. If you’re using any of the schemes shown on the lists or similar schemes, HMRC strongly

advises you to withdraw from them and settle your tax affairs to prevent building up a large tax bill. If you’re already speaking to someone in HMRC about your use of a tax avoidance scheme,

you should contact them to discuss this further. If you do not have an HMRC contact and you want to get out of a tax avoidance scheme, contact HMRC. REPORT A TAX AVOIDANCE SCHEME TO HMRC

You can report tax avoidance schemes and those offering you the schemes to HMRC. You can do this by using the report tax fraud or avoidance online service. You can submit this form

anonymously. You do not have to give your name, address or email. If you cannot use the online form, you can contact HMRC. 4. DETAILS OF HOW EACH NAMED SCHEME IS CLAIMED TO WORK COUNTRYWIDE

PARTNERS LIMITED * Scheme users enter into an employment contract with Countrywide Partners Limited (CPL). The contract states that the user will be paid a salary equivalent to National

Minimum Wage (NMW) or National Living Wage (NLW) plus holiday pay. It also provides that any additional payments will constitute as a ‘Bonus’. * Users will also enter into a ‘Bonus,

Incentive or Pay Scheme Offer’ called the ‘Bonus Agreement’ and a separate Loan Agreement with CPL. The Loan Agreement states that CPL promises to loan certain monies, secured against any

‘bonus’ payments, made to the user as pursuant to the terms of the bonus agreement. * CPL invoice the recruitment agency or end user for the services carried out by the scheme user. CPL

retain 15% from the gross amount received. * CPL pay the user: * the NMW or NLW salary and any holiday pay through the payroll with Income Tax and National Insurance contributions deducted

from these earnings * the remaining balance is paid to the user in the form of a loan (that will supposedly be repaid by future bonus payments) – bonus payments are taxable income, but tax

is not paid on the loans.   SAXONSIDE LIMITED – SAXONSIDE SHARE GROWTH * The scheme users enter into an employment contract with Saxonside Limited (SAX) and are issued a share in the cell in

Omni Contractors Limited (OCP) that is unique to the scheme user. * Scheme users submit timesheets to SAX who then invoice the agency or end client for the work done. * SAX retains

approximately 10% of the invoiced amount, which is allegedly for covering any capital gains tax (CGT) the scheme user may be liable to in relation to the share. SAX claim they will return

this amount to the scheme user when their CGT liability is confirmed. * SAX retains a further amount of around 18% to 21% and pay the scheme user a National Minimum Wage salary. * OCP pays

the scheme user a separate amount without deductions for tax and National Insurance contributions. This supposedly represents the increased share value held in OCP. 5. EXPLANATION OF TERMS

USED ACCELERATED PAYMENT NOTICE (APN) An APN is a requirement to pay an amount on account of tax or National Insurance contributions. HMRC issues APNs to taxpayers involved in avoidance

schemes where an SRN has been allocated under the DOTAS rules, or ones in respect of which HMRC has given a General Anti-Abuse Rule counteraction notice. They can also be issued to taxpayers

who have received a follower notice in relation to a scheme. AUTHORISED OFFICER An authorised officer is a person that has been authorised by the Commissioners for HMRC for the purpose of

the 2022 legislation (section 86 Finance Act 2022). Only authorised officers can authorise the publication of information under the section. For the purposes of this legislation, authorised

officers will be senior civil servants and independent of any compliance activity relating to the tax avoidance scheme in question. CONDUCT NOTICE A conduct notice forms part of the POTAS

regime. It is issued by HMRC and imposes conditions on a promoter that must be complied with. CONNECTED PERSONS For the purposes of the 2022 legislation, a person is a connected person in

relation to a scheme, or to a promoter of a scheme, if the person is within one of 5 specified categories. Read more information about connected persons. ENABLER Any person who is

responsible, to any extent, for the design, management, marketing or otherwise facilitating another person to enter into abusive tax arrangements. ENTITY A business entity is an organisation

created to conduct business, engage in a trade or partake in similar activities. For example, a ‘partnership’, ‘company’ or ‘limited liability partnership’. FOLLOWER NOTICE A follower

notice can be given to a person who has used an avoidance scheme that has been shown in another person’s litigation to be ineffective. The follower notice tells the person they may be liable

to a penalty of up to 30% of the tax and/or NICs in dispute if they do not amend their return or settle their dispute. PROMOTER A person is a promoter if they are carrying on a business

that includes, or has included, the design, marketing, implementation, organisation or management of tax avoidance schemes. A ‘person’ could be an individual, company or partnership. SCHEME

REFERENCE NUMBER (SRN) A SRN is a number allocated to a tax avoidance scheme by HMRC at the time the scheme is disclosed to them, or, where a scheme has not been disclosed and HMRC

reasonably suspect that the scheme should have been disclosed. It allows HMRC to identify and track users of disclosed tax avoidance schemes. The allocation of a SRN does not mean that HMRC

has in any way approved or cleared a scheme for use. STOP NOTICE Stop notices may be issued to a person who HMRC suspects is promoting an avoidance scheme, which they consider does not work.

If a promoter does not comply with a stop notice they would meet a POTAS threshold condition. This may lead to HMRC giving them a conduct notice. MONITORING NOTICE A monitoring notice forms

part of the POTAS regime. It is issued by HMRC where a promoter breaches a requirement in a conduct notice. A promoter that is subject to a monitoring notice is referred to as a monitored

promoter and is subject to various disclosure requirements and other obligations and a strict penalty regime where those requirements or obligations are not met. SUPPLIER Supplier refers to

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

person may be involved in the supply of the scheme. Back to top