06 July 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 6 July 2026 with the addition of:
- Buckingham Administration Co. Ltd (incorporated in Belize)
HMRC has provided additional information regarding its interpretation of the scheme and how they work:
A scheme user (for example a company or self-employed person) contributes to an offshore trust (the Buckingham Administration Co. Ltd Nova Trust 1, the GCWealth Administration LLC Nova Trust 1 or some other trust) and claims the contribution as a deductible Corporation Tax or Income Tax expense. If the user is a company, the money claimed to have been contributed to the Trust is subsequently transferred to the company’s director, typically via another company they are a director and/or shareholder of. The director or self-employed person claims to have received this money from the trust either by way of loans, or to be holding it in a fiduciary capacity. No Income Tax or National Insurance contributions (NICs) are paid by the director or the self-employed person on amounts they claim to receive from the trust.
Nova Trust deeds include a provision with the claimed effect that any enquiries into the scheme from HMRC will cause the trust to be void from the outset. In promotional material, it is claimed that its assets are deemed to be settled on another new trust with the same self-voiding provision, and that HMRC would have to open a new enquiry. HMRC considers this claim to be incorrect and open enquiries into an individual or company remain valid. It is HMRC’s view that the arrangements involving Nova Trusts are a continuation of the Remuneration Trust arrangements published by HMRC under Finance Act 2022 on 3 May 2023. Contributions to Nova Trusts are not allowable deductions for Income Tax or Corporation Tax purposes and funds received from the trust or retained by the user, or its directors, employees or others, are taxable as earnings. Recent tribunal decisions support this view (see Spotlight 61).
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.
