26 September 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 25 September 2023:
- Edge Umbrella Limited – the arrangements involve individuals providing their services to end clients or agencies through Edge Umbrella Limited (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
- Hamilton Bradbury Ltd – 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 Hamilton Bradley Ltd (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 (NMW)/National Living Wage salary (NLW) 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 NICs
- Olympus Contracting Limited – the arrangements involve users providing their services to end clients through Olympus Contracting Limited (OCL). The users sign a contract of employment that will pay them a basic salary at or around the rate of NMW or NLW salary which is subjected to income tax and NICs. Scheme users also receive a secondary payment. This secondary payment is paid by a third-party or by OCL itself without income tax or NICs being deducted.
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