22 May 2025
HM Revenue and Customs (HMRC) has added two new names and seven update to the current list of named tax avoidance schemes, promoters, enablers and suppliers.
The most recent update was on 15 April 2025 with the addition of:
- Compas Limited (incorporated in the Isle of Man)
- NM Recruitment Services Ltd
Updates:
- ABC Umbrella Ltd
- MLG Pay Limited
- Veqta Ltd
- On the Box Pay Ltd
- The Umbrella Agency Limited
- Umbrella Link Ltd
HMRC has provided additional information regarding its interpretation of the schemes and how they work:
Compas Limited
“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.”
NM Recruitment Service Ltd
“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 to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.”
It is important to spread awareness of these schemes and to not get caught up in them. But, if you think you are involved in one, or know of someone who is, you can contact HMRC for assistance and guidance.
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