02 August 2023

HM Revenue and Customs (HMRC) has updated the list of named tax avoidance schemes, promoters, enablers and suppliers.

The below schemes have been added as of 2 August 2023:

  • Apricot Umbrella Limited (AUL) – 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.
  • Countrywide Partners Limited (CPL) – 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 (NMW) or National Living Wage (NLW) salary which is taxed under PAYE. CPL pay the remaining amount in the form of a loan. This amount is not taxed under PAYE.

The list of tax avoidance schemes subject to a Stop Notice is also accessible, here.


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