05 June 2026
HM Revenue and Customs (HMRC) has added one new name to the current list of named tax avoidance schemes, promoters, enablers and suppliers.
The most recent update was on 4 June 2026 with the addition of:
HMRC has provided additional information regarding its interpretation of the scheme and how they work:
Individuals provide services to end clients as employees of PPSL. Employees receive part of their remuneration from PPSL 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.
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 suspects that the arrangement is targeted at healthcare professionals. HMRC advise employees of PPSL to familiarise themselves with Spotlight 60 and to satisfy themselves that the correct amount of tax is being deducted on their income.
Another update was on 30 April 2026 with the addition of:
HMRC has provided additional information regarding its interpretation of the scheme and how they work:
HMRC suspect scheme users sign a contract of employment and a secondary agreement with AOL, a company based in the Cayman Islands. AOL utilise the support of a UK umbrella company called IUL, who enter into an agreement for administrative services with AOL. IUL then contract the scheme user’s services to an end client, sometimes via an intermediary/agency. The end client pays the intermediary/agency for the scheme user’s services, who in turn pay IUL. IUL pay AOL who then pay a salary to the scheme users, at the minimum rate permitted under the National Minimum Wage Act 1998, with Income Tax and National Insurance contributions (NICs) deducted. AOL also make a second payment to the scheme users, described as a loan and made pursuant to the secondary agreement, without deductions of Income Tax and NICs.
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.
Information provided in this news article may be subject to change. Please make note of the date of publication to ensure that you are viewing up to date information.
