Corporate report

Current list of named tax avoidance schemes, promoters, enablers and suppliers

Updated 2 May 2024

© Crown copyright 2024

This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gov.uk.

Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.

This publication is available at https://www.gov.uk/government/publications/named-tax-avoidance-schemes-promoters-enablers-and-suppliers/current-list-of-named-tax-avoidance-schemes-promoters-enablers-and-suppliers

1. How to use the information on this page

This is not a complete list of all tax avoidance schemes currently being marketed. Neither is it a complete list of all promoters, enablers and suppliers.

If you are involved in any of the tax avoidance schemes shown on this page, or recognise any of the promoters, enablers or suppliers, and are not already talking to HMRC about your tax position you should contact HMRC as soon as possible. There is more information about how to do this below. You can also report a tax avoidance scheme to HMRC.

There are other schemes, promoters, enablers and suppliers that HMRC cannot publish information about at this time. This may be because:

  • HMRC is gathering information about the promoter, enabler, supplier or avoidance schemes being marketed
  • HMRC is considering representations from a promoter, enabler or supplier
  • the appeal period for not withdrawing a stop notice has not ended
  • HMRC is not aware of the tax avoidance scheme, promoter, enabler or supplier

If a tax avoidance scheme is not shown in the list, this does not mean that the scheme works or is in any way approved by HMRC. HMRC does not approve tax avoidance schemes for use.

Read more information about what HMRC can publish, and why.

2. List of named tax avoidance schemes, promoters, enablers and suppliers

This list is presented in alphabetical order and will be updated regularly.

The most recent update was on 2 May 2024 with the removal of 5 entries in line with Finance Act 2004.

If you want to get more information about a company or its directors, you can check Companies House.

You can also check the list of tax avoidance schemes subject to a Stop Notice.

ABC Umbrella Ltd

Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation ABC Umbrella Ltd / Kevin Cutler (Director of ABC Umbrella Ltd) / Krevit Ltd (Incorporated in Cyprus) / Giannakis Fysentzou (Director of Krevit Ltd)
Addresses of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation ABC Umbrella Ltd: 1921 Building C/O Aspirations Accountancy, East Malling Business Centre, New Road, East Malling, United Kingdom, ME19 6BJ / Krevit Ltd: Stratigou Timagia, 15, Linda Court, Floor 3, 6051, Larnaca, Cyprus
Date of publication 9 August 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The arrangements involve individuals providing their services to end clients or agencies through ABC Umbrella Limited as their employer. The individuals also enter an agreement with Krevit Ltd where individuals grant the right to enter an Annuity Agreement in exchange for payments (the Grantee Payments). The individuals receive payment from ABC Umbrella Limited. 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 ABC Umbrella Limited on behalf of Krevit Ltd. It is also HMRC’s view that the Grantee Payments are additional disguised income for services provided by individuals through ABC Umbrella Limited, and the entire payment should therefore be subject to tax and NICs.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies. HMRC has now allocated a Scheme Reference number, 60705829, to the arrangements on 26 July 2023 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes’.

Abchurch Ltd

Details of persons suspected of promoting the scheme Abchurch Ltd
Addresses of persons suspected of promoting the scheme 128 City Road, London, EC1V 2NX
Date of publication 29 February 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Individuals provide services to end clients as employees of Abchurch Ltd. Employees receive part of their Abchurch Ltd remuneration at a rate close to the National Minimum Wage or National Living Wage with Income Tax and National Insurance contributions (NICs) deducted. Employees receive the balance of their remuneration, disguised as a loan, credit, or other payment without Income Tax or NICs deducted.
Any other information HMRC considers relevant to publish about these schemes It is HMRC’s view that all remuneration paid to employees of Abchurch Ltd is taxable. HMRC has previously published Spotlight 60 on Disguised remuneration schemes involving agency workers and contractors employed by umbrella companies. HMRC is aware that some Umbrella Companies operate more than one scheme, for example, a standard compliant scheme and a non-compliant scheme. HMRC advises employees of Abchurch Ltd to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Acacia Management Services Limited

Name of promoter of scheme and connected person Acacia Management Services Limited (AMS) / Jake Hamill (former director of Acacia Management Services Limited)
Address of promoter of scheme 27 Byrom Street, Manchester, M3 4PF / Former address: Office 2.24 Edward Pavilion, Albert Dock, Liverpool, L3 4AF
Date of Publication 11 April 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Scheme users enter into a contract of employment and an option grant agreement with AMS. AMS invoice recruitment agencies for the services provided by the scheme users. On receipt of payment from the recruitment agencies, AMS pays a National Minimum Wage or National Living Wage salary to the scheme users with tax and National Insurance Contributions (NICs) deducted. AMS also makes a second payment to scheme users, described as an ‘option grant’, with no tax or NICs deducted.
Any other information HMRC considers relevant to publish about these schemes HMRC’s view is that the option grant payments are no different to normal income, and tax and NIC’s are payable. HMRC have previously published information about the tax avoidance arrangements used by some umbrella companies Spotlight 60. 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 of AMS to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. HMRC has evidence that AMS predominantly worked with recruitment agencies in the medical sector.

Alphasaint Ltd

Details of persons suspected of promoting the scheme Alphasaint Ltd (ASL)
Addresses of persons suspected of promoting the scheme 71-75 Shelton Street, London, England, WC2H 9JQ
Date of Publication 11 April 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The scheme users’ total remuneration for their contracts with ASL is artificially separated into two elements. The first element is a salary with Income Tax (IT) and National Insurance Contributions (NICs) deducted. The second element is paid without deduction of IT and NICs by ASL and it is claimed to not count as employment income.
Any other information HMRC considers relevant to publish about these schemes HMRC’s view is that both elements of the payment should be treated as ‘normal income / as the users’ salary’ and is therefore subject to IT and NICs. HMRC has 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, such as a standard compliant scheme and a non-compliant scheme. HMRC advise employees of ASL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

AML Tax (UK) Limited

We have published details of 3 schemes that have been supplied and/or promoted by AML Tax (UK) Limited:

  • a scheme utilising an annuity arrangement
  • a scheme utilising an employee benefit trust (EBT)
  • a scheme utilising a split contract

AML Tax (UK) Limited – Annuity Arrangements

Name of scheme Annuity Arrangements
Name of promoter or supplier of scheme AML Tax (UK) Limited (AML)
Address of promoter or supplier of scheme 1st Floor, Blackfriars House, Parsonage, Manchester M3 2JA
Date of publication 19 January 2023
Scheme Reference Number (SRN) 64011522
Date SRN allocated to the scheme 19 May 2022
Legislation under which this scheme/promoter has been named Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based Section 455 of the Corporation Tax Act 2010 (CTA)
How the scheme is claimed to work – summary There is usually a pre-existing loan between a director/shareholder (the ‘scheme user’) and their company. The user signs an ‘option agreement’ with the company. In return for signing the option agreement, the company releases the user from their obligation to repay the loan. The ‘option’ enters the user into an annuity agreement with the company, under which the user is required to pay an annuity to the company for life, if exercised. However, an ‘early encashment’ mechanism within the annuity agreement enables the company to cancel its option rights for a nominal fee. The company will usually cancel the option so that the scheme users do not pay the annuity or loan repayment. Therefore, the company does not pay Corporation Tax on the loan.
Judicial rulings relating to the scheme HMRC v AML Tax (UK) Ltd [2022] UKFTT 114

AML Tax (UK) Limited – AML Prefunded EBT

Name of scheme AML Prefunded EBT
Name of promoter or supplier of scheme AML Tax (UK) Limited (AML)
Address of promoter or supplier of scheme 1st Floor, Blackfriars House, Parsonage, Manchester M3 2JA
Date of publication 19 January 2023
Scheme Reference Number (SRN) 71821313
Date SRN allocated to the scheme 19 May 2022
Legislation under which this scheme/promoter has been named Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work – summary An offshore company linked to AML creates and funds an employee benefit trust (EBT). The offshore company sells its right to nominate a beneficiary of the EBT to a company that the scheme users are directors of (the ‘user company’). The user company nominates the scheme users as beneficiaries and assigns them the debt that is owed to the offshore company via the director’s loan account (DLA); this debt is left outstanding. The outstanding debt is used to offset other loans received through the DLA, therefore avoiding Income Tax. The company also claims a Corporation Tax deduction for the amount of this assigned debt under employee costs.
Judicial rulings relating to the scheme HMRC v AML Tax (UK) Ltd [2022] UKFTT 114

AML Tax (UK) Limited – AML Split Contract

Name of scheme AML Split Contract
Name of promoters or suppliers of scheme AML Tax (UK) Limited (AML) / Denmedical UK Limited
Address of promoters or suppliers of scheme 1st Floor Blackfriars, Parsonage, Manchester M3 2JA (address same for both promoters / suppliers)
Date of publication 19 January 2023
Scheme Reference Number (SRN) 15062269
Date SRN allocated to the scheme 28 July 2022
Legislation under which this scheme/promoter has been named Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work – summary AML and Denmedical UK Limited promote the same scheme. A limited company splits the services provided by its director (the ‘scheme user’) into ‘fiduciary services’ and ‘consultancy services’. An offshore company contracts with the scheme user to supply their consultancy services to the limited company via the offshore company. The scheme user also signs a loan agreement with the offshore company in their capacity as trustee of a linked benefit trust. The scheme user is paid a notional salary from the limited company for fiduciary services, a loan from the linked trust and a notional retainer payment from the offshore company. The retainer payment and loan are both claimed to relate to ‘self-employed consultancy services’. The loan is made without Income Tax or National Insurance contributions deducted.
Judicial rulings relating to the scheme HMRC v AML Tax (UK) Ltd and Denmedical UK Ltd [2022] UKFTT 174

Apricot Umbrella Limited

Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation Apricot Umbrella Limited (AUL) / Mr Brian Ash (Former director of Apricot Umbrella Limited) / ADYE Ltd (Based in Cyprus) / Giannakis Fisentzou (Director of ADYE Ltd)
Addresses of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation Apricot Umbrella Limited: 20 North Lane, Canterbury, CT2 7PG / ADYE Ltd: 5-7 G&S Court, 4th Floor, Flat/Office 401, 6030, Larnaca, Cyprus
Date of publication 2 August 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work 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.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies. HMRC has now allocated a Scheme Reference number, 49908130, to the arrangements on 02 November 2023 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes’.

Bluemoore Associates Ltd

Details of persons suspected of promoting the scheme, or of being a connected person Bluemoore Associates Ltd (BAL) /Oliver Jenner (Sole director of BAL)
Addresses of promoters suspected of promoting the scheme Bluemoore Associates Ltd: 50 Princes Street, Ipswich, IP1 1RJ
Date of publication 28 June 2023
Publication last updated 1 December 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The arrangements involve users providing their services to end clients through BAL. The users sign a contract of employment that will pay them a basic salary at a rate of National Minimum Wage or National Living Wage which is subjected to tax and National Insurance contributions. Scheme users also receive a second payment. This second payment is paid by a third-party, or by BAL itself, without tax or National Insurance contributions being deducted.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 45 and Spotlight 60 guidance on disguised remuneration schemes involving umbrella companies based on similar arrangements. HMRC allocated a Scheme Reference number, 69178522, to the arrangements on 12 July 2023 under section 311 Finance Act 2004 ‘Disclosure of Tax Avoidance Schemes.’

Bluestar Financial Solutions Limited

Details of persons suspected of promoting the scheme, or of being a connected person Bluestar Financial Solutions Limited / Steven Alan Carridge (Director of Bluestar Financial Solutions Limited)
Address of promoters suspected of promoting the scheme Bluestar Financial Solutions Limited, 71-75 Shelton Street, London, WC2H 9JQ
Date of publication 17 November 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary The scheme user enters an employment contract with Bluestar Financial Solutions Limited who make composite payments to the scheme users for services provided by the user. The first element is a salary with tax and National Insurance contributions (NICs) deducted, and a secondary element described as a ‘propelled payment’ with no tax and NICs deducted.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 60 on Disguised remuneration schemes involving agency workers and contractors employed by umbrella companies.

Buckingham Wealth Ltd

We have published entries that relate to 2 schemes operated by Buckingham Wealth Ltd:

  • scheme 1 – published under Finance Act 2022
  • scheme 2 – published under Promoters of Tax Avoidance Schemes regime
Scheme entry  1
Name of promoter or supplier of scheme  Buckingham Wealth Ltd (BWL) (incorporated in Belize) / Minerva Services Ltd (MSL) (incorporated in Belize)
Address of promoter or supplier of scheme Buckingham Wealth Ltd (Belize), No. 1 Orchid Garden Street, Belmopan, Belize / Minerva Services Ltd (Belize), PO Box 445, Suite 5, Garden City Plaza, Mountainview Boulevard, Belmopan, Belize
Date of publication 3 May 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary Under the Umbrella Remuneration Trust (URT) arrangements, a scheme user (for example a company or a self-employed person) contributes to an offshore remuneration trust and claims the contribution as a deductible Corporation Tax or Income Tax expense. The money claimed to have been contributed to the trust is subsequently transferred, typically via another company, to the company’s director or back to the self-employed person. The director claims the funds received this way are held as ‘loans’ or held in a fiduciary capacity. HMRC has determined that these amounts are subject to tax, and recent tribunal decisions for the corporate users support this.
Any other information HMRC considers relevant to publish about these schemes We have published a document that shows BWL and MSL (the ‘Promoters’) encouraging URT users to sign a declaration that claims the URT to which contributions were made is void, and HMRC must close its enquiries as they are invalid, and instead make a ‘replacement’ contribution to a newly founded ‘Nova’ Trust. HMRC considers this to be an acknowledgement by the Promoters that the URT arrangements do not work. The enquiries remain valid and HMRC considers that the Nova Trust arrangements are a continuation of the arrangements used by the URT, and therefore subject to tax and NICs. HMRC would encourage all users of the URT not to enter into Nova without obtaining independent advice.
Documents which are appropriate to publish Please find below a link to the page for published documents, including the document issued by the Promoters to clients – the document contains a summary of the Nova arrangement and a question-and-answer section. HMRC do not agree with the assertions made in this document. We are publishing it to aid understanding of how Nova is claimed to work; to demonstrate that the Promoters do not appear to believe their own tax avoidance scheme works; and to deter potential scheme users from trusting the claims made by these Promoters. Evidence of marketing material used by tax avoidance promoters and suppliers.
Scheme entry 2
Name of promoter Buckingham Wealth Ltd (incorporated in Belize)
Legislation under which this Stop Notice has been published Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published 10 November 2023
Date name of promoter subject to Stop Notice published 10 November 2023
POTAS publication List of tax avoidance schemes subject to a stop notice

Canopaye Limited

Details of persons suspected of promoting the scheme, or of being a connected person Canopaye Limited (CL) / Philip Jackson (director of Canopaye Limited) / Niall Bradley (previous director of Canopaye Limited)
Addresses of promoters suspected of promoting the scheme Canopaye Limited, The Charter Building, Charter Place, Uxbridge, UB8 1JG
Date of publication 23 February 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary The arrangements involve users providing their services to end clients through CL. The users also sign an agreement that sees the users grant CL an option on an Annuity Agreement. The result is the remuneration for their services is artificially separated into a salary and payments said to be in return for the option. No tax or National Insurance contributions are deducted in relation to the payments for the option.  
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 35 on disguised remuneration schemes involving annuity agreements based on a similar scheme.  

Charteris Management Ltd

Details of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation 1. Charteris Management Ltd (CML) / 2. Taurus Limited (Incorporated Isle of Man) / 3. Howe Consultancy Limited (Incorporated Isle of Man) / 4. Griffith Anderson Limited / 5. Integra Resourcing Ltd (Incorporated Malta) / 6. Jeceris Limited / 7. Ombros Solutions Limited
Addresses of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation 1. Charteris Management Ltd of Manchester Business Park, 3000 Aviator Way, Manchester, M22 5TG. / 2. Taurus Limited of 3rd floor, Atlantic House, 4-8 Circular Road, Douglas, Isle of Man, IM1 1AG. / 3. Howe Consultancy Limited of 3rd floor, Atlantic House, 4-8 Circular Road, Douglas, Isle of Man, IM1 1AG. / 4. Griffith Anderson Limited of 7 Bell Yard, London, WC2A 2JR. / 5. Integra Resourcing Ltd of Block 12, Office M1, Suite 106, Tigne Place, Tigne Street, Sliema, SLM3173, Malta. / 6. Jeceris Limited of Solway House Business Centre, Parkhouse Road, Kingstown, Carlisle, CA6 4BY. / 7. Ombros Solutions Limited of 33 Colston Avenue, Bristol, BS1 4UA.
Date of publication 24 November 2022
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary The scheme users enter into an employment contract with CML, providing their services to end clients through CML, sometimes via an agency. The scheme users may also sign a separate contract with a second party at the same time. See entries 2 to 7 of ‘Details of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation’ for a list of second parties. CML will invoice the end client or agency for the work and, after deducting a fee, pay the scheme user a salary at, or just above the National Minimum Wage and then pay the remaining funds to the second party. This is disguised as an ‘introducer fee’, as CML claim the second party introduced the scheme user to CML. The second party, after deducting a fee, then makes a larger payment to the scheme user, which may be labelled as a ‘loan’, ‘option’, or something else. Tax and National Insurance contributions are not paid on the second payment to the user.
Any other information HMRC considers relevant to publish about these schemes CML claim the payment to the second party is an ‘introducer fee’. This is not the case and these payments can clearly be seen as the balance of the amount the user raises on the timesheet they send to CML, most of which is to be paid on to the user by the second party and the rest retained by the second party as a fee. Tax and National Insurance contributions have not been paid on this second payment to the user. The scheme is targeted predominantly at physiotherapists, radiographers, nurses and social workers.

Compliant Pay Ltd

Details of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation  Compliant Pay Ltd / Ultimate Planning Ltd
Addresses of promoters suspected of promoting the scheme and addresses of those suspected of having any other role in relation to making the scheme available for implementation Ultimate Planning Ltd: 128 City Road, London, EC1V 2NX
Date of publication 28 June 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary The arrangements involve a scheme user providing their services to end clients or agencies through Compliant Pay Ltd, and then remuneration for the user’s services is artificially separated into a salary from Compliant Pay Ltd and a second larger payment from Ultimate Planning Ltd. The second payment, described as a ‘Capital Payment’, is made without payments for tax and National Insurance contributions.
Any other information HMRC considers relevant to publish about these schemes Compliant Pay Ltd went into liquidation on 25 April 2023. Their trading address prior to entering liquidation was: 128 City Road, London, EC1V 2NX. HMRC have now notified Compliant Pay Ltd that a Scheme Reference Number (SRN 13688608) has been allocated to the arrangements. You can find out what this means for you by reading the DOTAS guidance. HMRC have previously published Spotlight 60 on agency workers and contractors employed by umbrella companies.

Contractor Bureau Limited

Details of persons suspected of promoting the scheme, or of being a connected person Contractor Bureau Limited (CBL) / Emmanuel Forkuoh (Director of CBL)
Addresses of persons suspected of promoting the scheme 16 Upper Woburn place, London, WC1H 0AF
Date of Publication 14 March 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Scheme Users are employed by CBL and provide services to end clients. Users take part in a Bonus Arrangement and CBL pay advances to users on the bonus pot. Users then receive payment from CBL which consists of two elements. The first element is a salary with tax and National Insurance contributions (NICs) deducted, and the second element is an ‘advance’ without tax and NICs deducted. CBL claim that the advances are repaid wholly or partly, as bonus payments are made at some time in the future.
Any other information HMRC considers relevant to publish about these schemes It is HMRC’s view the salary and advances paid to employees of CBL should be subject to tax and NICs. HMRC have previously published Spotlight 60 guidance for agency workers and contractors employed by umbrella companies.

Contractorcare Ltd

Name of promoter Contractorcare Ltd
Date arrangements subject to Stop Notice published 2 March 2023
Date name of promoter subject to Stop Notice published 18 April 2024
POTAS publication List of tax avoidance schemes subject to a stop notice

Countrywide Partners Limited

Details of persons suspected of promoting the scheme Countrywide Partners Limited (CPL)
Addresses of persons suspected of promoting the scheme Suite 114, 25 Goodlass Road, Liverpool L24 9HJ
Date of publication 2 August 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work 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 or National Living Wage salary which is taxed under PAYE. CPL pay the remaining amount in the form of a loan. This amount is not taxed under PAYE.
Any other information HMRC considers relevant to publish about these schemes HMRC previously allocated a Scheme Reference Number (SRN) to the arrangements and notified CPL of this. SRN 20980718 was allocated on 18 April 2022. A scheme user may be required to enter into a Loan agreement and Bonus, Incentive or Pay Scheme Offer agreement. The purported loan element that scheme user’s receive may be described as an ‘ILO Bonus’.

Dalespay Ltd

Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation Dalespay Ltd (DL) / Austin Merritt (Director of DL) / Bestia Holdings Ltd (BHL) (Incorporated in Cyprus) / Giannakis Fysentzou (Director of BHL)
Addresses of persons suspected of promoting the scheme or having any other role in relation to making the scheme available for implementation Dalespay Ltd: 17 Olav Road, Richmond, England, DL10 4PU / Bestia Holdings Ltd: 5-7 G&S Court, 4th Floor, Flat/Office 401 6030, Larnaca, Cyprus
Date of publication 18 August 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The arrangements involve individuals providing their services to end clients or agencies through DL and entering into an agreement where individuals grant BHL a right to enter an Annuity Agreement in exchange for payments (the ‘Grantee Payments’). The individuals receive a payment from DL; 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, relates to the Grantee Payments, but paid by DL on behalf of BHL. It is also HMRC’s view that the Grantee Payments are additional disguised income for services provided by individuals through DL, and the entire payment should therefore be subject to tax and NICs.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies.

Easyway Umbrella Limited

Details of persons suspected of promoting the scheme, or of being a connected person Easyway Umbrella Limited
Addresses of promoters suspected of promoting the scheme Innovation House, 39 Mark Road, Hemel Hempstead Industrial Estate, Hemel Hempstead, HP2 7DN
Date of publication 27 July 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Individuals provide services to end clients as employees of Easyway Umbrella Limited. Employees receive part of their Easyway Umbrella Limited remuneration at a rate close to the National Minimum Wage or National Living Wage which is subject to Income Tax and National Insurance. Employees receive the balance of their remuneration, disguised as a loan, credit or other payment, without the deduction of Income Tax or National Insurance.
Any other information HMRC considers relevant to publish about these schemes HMRC considers the untaxed payments as normal income, and tax and National Insurance contributions are payable. HMRC have previously published information on umbrella companies offering to increase your take home pay Spotlight 45. HMRC are aware that some umbrella companies operate more than one scheme, eg a standard compliant scheme and a non-compliant scheme. HMRC advise employees of Easyway Umbrella Limited to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. 

Edge Umbrella Limited

Details of persons suspected of promoting the scheme, or of being a connected person Edge Umbrella Limited (EUL) / Darren Harding (Director of EUL / Joanna Fysentzou (former Director of EUL) / Deposlo Holdings Ltd (based in Cyprus) / Giannakis Fisentzou (Director of Deposlo Holdings Ltd)
Addresses of promoters suspected of promoting the scheme Edge Umbrella Limited, 78 York Street, London, W1H 1DP / Deposlo Holdings Ltd, 15 Linda Court, Floor 3, 6051, Lanaka, Cyprus
Date of publication 25 September 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The arrangements involve individuals providing their services to end clients or agencies through 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.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies. Together with HMRC, The Committee of Advertising Practice (CAP) Compliance team has been taking market-wide action about the advertising of tax arrangements. As part of this work, the Advertising Standards Authority (ASA) published details of Edge Umbrella Limited on their website under ‘Non-compliant online advertisers’. Misleading claims and omissions have been made about the tax arrangements offered on the Edge Umbrella website. This followed on from an Enforcement Notice jointly issued with CAP that provided guidance to promoters of tax arrangement schemes. You can read a copy of an Enforcement Notice. 

Excala Solutions Limited

Details of persons suspected of promoting the scheme Excala Solutions Limited (ESL)
Address of promoters suspected of promoting the scheme Excala Solutions Limited, 71-75 Shelton Street, Greater London, WC2H 9JQ
Date of publication 17 November 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The scheme user enters an employment contract with ESL. ESL then makes a single payment to the scheme user, but this is artificially separated into two elements. The first element is a salary paid at or around National Minimum Wage or National Living Wage with tax and National Insurance contributions (NICs) deducted. The secondary element is described as a ‘propelled payment’ with no tax and NICs deducted.
Any other information HMRC considers relevant to publish about these schemes 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 tax and NICs. HMRC have previously published Spotlight 60 guidance 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, eg a standard compliant scheme and a non-compliant scheme. HMRC advise employees of ESL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Flex Payroll and Accounting Services Ltd

Name of scheme FlexPAS Advance payment
Name of promoter of scheme and connected persons Flex Payroll and Accounting Services Ltd (Flex PAS) / Russell Lee Forshaw (former Director of Flex PAS)
Address of promoter of scheme Flex Payroll and Accounting Services Ltd, Stapeley House, London Road, Stapeley, Nantwich, England, CW5 7JW
Date of publication 1 February 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Flex PAS enters into a contract of employment with scheme users. The scheme users provide their services to the ‘end client’ and Flex PAS then invoice the end client for those services. Flex PAS pays an amount to the scheme users equivalent to the National Minimum Wage or National Living Wage with Income Tax and National Insurance contributions (NICs) deducted. Flex PAS also makes a second payment to the scheme user, described as an ‘advance payment’, with no Income Tax and NICs deducted.
Any other information HMRC considers relevant to publish about these schemes HMRC has previously published Spotlight 60 about the tax avoidance used by some umbrella companies. HMRC is aware that some Umbrella Companies operate more than one scheme, for example a standard compliant scheme and a non-compliant scheme. The Flex PAS website advertises its services to Doctors, Nurses and Social Workers in the public sector. HMRC advises employees of Flex PAS to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Focus Contractor Limited

Name of promoter Focus Contractor Limited
Legislation under which this Stop Notice has been published Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published 13 April 2023
Date publication was last updated 7 June 2023
Date name of promoter subject to Stop Notice published 12 October 2023
POTAS publication List of tax avoidance schemes subject to a stop notice

Griffith Anderson Limited

Name of promoters of scheme Griffith Anderson Limited / Umbrella Contracts Limited (UCL)
Address of promoters of scheme Griffith Anderson Limited: 7 Bell Yard, London, WC2A 2JR / Umbrella Contracts Limited: Kintail House, Beechwood Park, Inverness, IV2 3BW
Date of publication 1 December 2023
Scheme Reference Number (SRN) 05773156
Date SRN allocated to the scheme 4 January 2023
Legislation under which this scheme/promoter has been named Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA) / Part 7A of ITEPA 2003 – Employment income provided through third parties
How the scheme is claimed to work- summary Scheme user signs an employment contract with UCL. The UCL contract states the user will be paid a salary equivalent to the National Minimum Wage (NMW) along with any commission to be paid under the ‘Commission Plan’ referred to in Schedule 1 of the contract. UCL invoices the end client. The scheme user is later provided with a copy of the ‘remittance note’ that the agency/end client sent to UCL. This confirms the scheme user’s rate of pay and hours worked. In accordance with the employment contract, UCL pays the user a NMW salary with tax and National Insurance contributions (NICs) deducted. Griffith Anderson Limited also makes a payment, but this is made without deductions for tax or NICs.

Hamilton Bradbury Ltd

Name of promoter or supplier of scheme Hamilton Bradbury Ltd (HBL) (registered in the UK)
Addresses of promoters suspected of promoting the scheme Hamilton Bradbury Ltd, Pacific House, Relay Point, Wilnecote, Tamworth, Staffordshire, B77 5PA
Date of publication 25 September 2023
Scheme Reference Number (SRN) 81003536
Date SRN allocated to the scheme 28 February 2023
Legislation under which this scheme/promoter has been named Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work – summary 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 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/National Living Wage salary 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 National Insurance contributions.
Judicial rulings relating to the scheme  HMRC v Hamilton Bradbury Limited (in liquidation) UKFTT 99

Hive Umbrella Ltd

Name of promoter or supplier of scheme Hive Umbrella Ltd
Legislation under which this Stop Notice has been published Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published 10 November 2023
Date name of promoter subject to Stop Notice published 10 November 2023
POTAS publication List of tax avoidance schemes subject to a stop notice

Integra Resourcing Limited

Name of promoter or supplier of scheme  Integra Resourcing Ltd – registered in Malta (IRL) / Target Umbrella Ltd – registered in the UK (TUL)
Address of promoter or supplier of scheme Integra Resourcing Limited, Block 12 Office M1 Suite 106, Tigne Place, Tigne Street, Sliema, Malta, SLM 7173 / Target Umbrella Limited, 6 Margaret Street, Newry, Northern Ireland, BT34 1DF
Date of publication 23 February 2023
Scheme Reference Number (SRN) 79326711
Date SRN allocated to the scheme 12 August 2022
Legislation under which this scheme/promoter has been named Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work – summary Users sign separate employment contracts with IRL and TUL. Users also sign an ‘Overarching Agreement’ with IRL to provide ‘loans’ to the user. TUL sign a contract for services with the agency or the end client to provide the services of the user. TUL then invoices the end client for the work undertaken by the user. TUL pay users a salary in line with the National Minimum Wage Act for time worked and pays the remaining amount to IRL. IRL then pays the user a second nominal salary, per payroll run, usually below £10, and a larger amount, described as a ‘loan’. The ‘loan’ amount is not taxed.

IP Global Consulting Ltd

Details of persons suspected of promoting the scheme IP Global Consulting Ltd (IPG)
Addresses of promoters suspected of promoting the scheme Registered office: 63-66 Hatton Garden, London, EC1N 8LE / Trading address: 54 St. James Street, Liverpool, L1 0AB
Date of publication 9 August 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary IPG invoices a recruitment agency for the services provided by a scheme user. On receipt of payment from the recruitment agency, IPG pays a National Minimum Wage amount to the user with tax and National Insurance contributions (NICs) deducted. IPG also makes a second payment to the user, described as an ‘advance’, without tax or NICs deducted.

MLG Pay Limited

Details of persons suspected of promoting the scheme MLG Pay Limited (MLG)
Addresses of persons suspected of promoting the scheme Suite 101, 89 High Street, Sidcup, DA14 6DW
Date of publication 21 December 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The scheme user’s total remuneration for their contracts with MLG is artificially separated into two elements. The first element is a salary with Income Tax and National Insurance contributions (NICs) deducted. The second element is paid without deduction of Income Tax and NICs by MLG. This second element is claimed to be for an option grant or sometimes referred to as ‘benefits in kind’.
Any other information HMRC considers relevant to publish about these schemes HMRC’s view is that both elements of the payment should be treated as ‘normal income/as the user’s salary’, and is therefore subject to 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, such as a standard compliant scheme and a non-compliant scheme. HMRC advise employees of MLG to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income. 

Olympus Contracting Limited

We have published 2 entries that relate to this scheme operated by Olympus Contracting Limited:

  • the first entry is published under the Finance Act 2022
  • the second entry is published under Promoters of Tax Avoidance Schemes regime
Details of persons suspected of promoting the scheme, or of being a connected person Olympus Contracting Limited (OCL) / Jordan Dobney (former director of OCL) / Oliver Ames – sole director of OCL
Addresses of promoters suspected of promoting the scheme Olympus Contracting Limited, 63-66 Hatton Garden, London, EC1N 8LE
Date of publication 25 September 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The arrangements involve users providing their services to end clients through OCL. The users sign a contract of employment that will pay them a basic salary at or around the rate of National Minimum Wage or National Living Wage salary which is subjected to Income Tax and National Insurance contributions (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.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 45 and Spotlight 60 guidance on disguised remuneration schemes involving umbrella companies based on similar arrangements.
Legislation under which this Stop Notice has been published Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published 7 December 2023
Date name of promoter subject to Stop Notice published 21 March 2024
POTAS publication List of tax avoidance schemes subject to a stop notice

PAYE Services Limited

We have published 2 entries that relate to this scheme operated by PAYE Services Ltd:

  • the first entry is published under the Finance Act 2022
  • the second entry is published under Promoters of Tax Avoidance Schemes regime
Details of persons suspected of promoting the scheme, or of being a connected person  PAYE Services Limited (PSL) / Simon Peter Whitehead (Director of PSL)
Addresses of promoters suspected of promoting the scheme PAYE Services Limited, 7 Bell Yard, London, WC2A 2JR
Date of publication 28 June 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary   Arrangements involve users signing a ‘Contract for Employment’ with PAYE Services Limited (PSL) that will pay them at a rate of National Living Wage (NLW) for each hour worked. They also sign a ‘Master Advance Agreement’. The user provides services to the end client and submits timesheets to PSL for the work done. PSL pays the user a single payment comprising of the NLW salary (with any holiday pay) and the Advance. The payment in relation to the Advance is made without the deduction of Income tax or National Insurance contributions.
Any other information HMRC considers relevant to publish about these schemes PSL sells its services via the website PAYE.com. PSL claims that it commits to provide further benefits to its employees, and that it is obliged to make employee incentivisation payments from its gross profits in the form of contributions to an ‘Investment Employee Incentivisation Scheme’ (IEIA); where it intends to invest these contributions in a Cayman hedge fund to generate further profits for its Beneficiaries. HMRC has seen no evidence to suggest this exists or takes place.
Legislation under which this Stop Notice has been published Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published 27 July 2023
Date name of promoter subject to Stop Notice published 10 November 2023
POTAS publication List of tax avoidance schemes subject to a stop notice

PAYEme Ltd

Name of promoter PAYEme Ltd
Date arrangements subject to Stop Notice published 2 March 2023
Date name of promoter subject to Stop Notice published 18 April 2024
POTAS publication List of tax avoidance schemes subject to a stop notice

Payeworx Ltd

Details of persons suspected of promoting the scheme Payeworx Ltd (PWL) / Contractor Buddy PCC Limited (CBP) (Incorporated in Isle of Man)
Addresses of promoters suspected of promoting the scheme Payeworx Ltd, Newspaper House, Tannery Lane, Penketh, Warrington, Cheshire, WA5 2UD / Contractor Buddy PCC Limited, 2nd Floor, Murdoch Chambers, South Quay, Douglas, Isle of Man, IM1 5AS
Date of publication 24 August 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The scheme user enters into an employment contract with PWL, and the scheme user’s Personal Service Company (PSC) is issued a share in CBP, a connected protected cell company based in the Isle of Man (IOM). PWL pay the scheme user a salary that is around the minimum amount required by the National Minimum Wage Act 1998. CBP make a separate larger payment without deducting Income Tax and National Insurance contributions to the scheme user’s PSC, supposedly for a dividend. CBP deduct around 2% from the larger payment as a fee, and a further 19% which they claim is Corporation Tax (CT). However, the rate of CT in the IOM is 0%. The scheme users are expected to distribute the alleged dividend amount as they see fit.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 60 guidance on Disguised remuneration schemes.

Pay Rec Limited

Details of persons suspected of having any other role in relation to making the scheme available for implementation. Pay Rec Limited (PRL)
Addresses of persons suspected of having any other role in relation to making the scheme available for implementation 1 Piccadilly Business Centre, Aldow Enterprise Park, Manchester, United Kingdom, M12 6AE
Date of publication 31 August 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Scheme users enter into an employment contract with PRL, which also invites them into a bonus scheme. PRL pays the scheme users a salary around the National Minimum Wage or National Living Wage with Income Tax and National Insurance contributions (NICs) deducted. At, or around the same time, the scheme users also receive a second payment, described as an advance against future bonus payments. This is paid without Income Tax and NICs deducted.
Any other information HMRC considers relevant to publish about these schemes It is HMRC’s view that the ‘advances’, paid against future bonus payments, are no different to normal income, and are therefore taxable. HMRC have previously published Spotlight 60 guidance for agency workers and contractors employed by umbrella companies. HMRC advise employees of PRL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Paystone Services Limited

Details of persons suspected of promoting the scheme Paystone Services Limited (PSL) (also known as Artifact Services)
Addresses of persons suspected of promoting the scheme 48 West George Street, Clyde Offices, 2nd Floor, Glasgow, Scotland, G2 1BP
Date of publication 1 February 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work PSL pay scheme users a salary, which is approximately at the National Minimum Wage or National Living Wage rate, with tax and National Insurance contributions (NICs) deducted. However, they also receive a secondary payment without deduction of tax and NICs. This may be labelled as ‘Share payment’, ‘Option payment’ or something else. The secondary payment is the remaining balance of their contractual payment for the work carried out, minus a fee that PSL deduct for the operation of the scheme.
Any other information HMRC considers relevant to publish about these schemes The scheme is targeted predominantly at workers within health, tech and energy sectors. Those in health, include doctors, nurses, speech therapists and podiatrists. HMRC do not accept these arrangements work as claimed. Tax and NICs should be accounted for on both payments under PAYE as they are made in respect of work carried out by the scheme user. It is HMRC’s view that the two payment arrangements are set up purely to facilitate a disguised remuneration tax avoidance scheme. HMRC is aware that some umbrella companies operate more than one scheme, for example a standard compliant scheme and a non-compliant schemes. HMRC advise employees of PSL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Peak PAYE Limited

Name of promoter Peak PAYE Limited
Legislation under which this Stop Notice has been published Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published 13 April 2023
Date name of promoter subject to Stop Notice published 7 June 2023
POTAS publication List of tax avoidance schemes subject to a stop notice

Prime Umbrella Services Ltd

We have published 2 entries that relate to this scheme operated by Prime Umbrella Services Ltd:

  • the first entry is published under the Finance Act 2022
  • the second entry is published under Promoters of Tax Avoidance Schemes regime
Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation Prime Umbrella Services Ltd / Adam Whitehead (Director of Prime Umbrella Services Ltd) / Wilson Costello Limited / Jonathan Milne (Director of Wilson Costello Limited)
Addresses of persons suspected of promoting the scheme Prime Umbrella Services Ltd, 128 City Road, London, United Kingdom, EC1V 2NX
Date of publication 31 August 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Arrangements involve a user providing their services to end clients/recruitment agencies through Prime Umbrella Services Ltd and receiving 2 payments, one equivalent to National Minimum Wage (NMW) or, if applicable, the National Living Wage (NLW) salary and a second payment, described as a ‘pass through item’, on behalf of Wilson Costello Limited. The result is that the total remuneration for the users’ services is artificially separated into 2 payments. The first is a salary (equivalent to NMW/NLW) with tax and National Insurance contributions (NICs) deducted, and a second payment which is made without tax or NICs deducted.
Any other information HMRC considers relevant to publish about these schemes HMRC have allocated Scheme Reference Number 79390150 to these arrangements. You can find out what this means for you by reading the DOTAS guidance at Disclosure of tax avoidance schemes. HMRC have also previously published Spotlight 60 guidance on Disguised remuneration schemes warning agency workers and contractors employed by umbrella companies.
Legislation under which this Stop Notice has been published Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published 18 April 2024
Date name of promoter subject to Stop Notice published 18 April 2024
POTAS publication List of tax avoidance schemes subject to a stop notice

Procorre LLP

Details of persons suspected of promoting the scheme, or of being a connected person Procorre LLP (Registered in Singapore) / Corre Holdings SA (Registered in Switzerland) / Mr Darren Patrick-Green (also known as Mr Darren Green) / Mr Jason Bougourd / Ms Alizeh Nanji
Addresses of persons suspected of promoting the scheme, or of being a connected person Procorre LLP: 33 Ubi Avenue 3, #08-61, Singapore 408868, Republic of Singapore / Corre Holdings SA: Rue du Rhône 118 Genève, GENÈVE, 1204 Switzerland
Date of publication 29 February 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Scheme users and their personal service companies (PSCs) join and become members in Procorre LLP (Procorre). The PSC’s then enter into contracts to provide the services of the scheme users to end clients. The PSC’s invoices the end clients [on behalf of Proccore] and transfer the income received to Procorre. Procorre return the income to the PSC’s and the users after deducting a fee. The income is returned via direct payment to the PSC’s bank accounts, and in the form of untaxed drawings, pre-paid expense cards and business development fund payments all provided by Procorre.
Any other information HMRC considers relevant to publish about these schemes It is HMRC’s view that the drawings, pre-paid expense cards and business development fund payments received by users represent the rewards for their services provided to end clients and should therefore be subject to Income Tax and National Insurance contributions. HMRC have previously issued a Spotlight on Disguised Renumeration Asset Transfer Arrangements intended to avoid the loan charge. The individuals named are connected persons due to their control over the LLP. Mr Patrick-Green is the Ultimate Beneficial Owner of Corre Holdings SA (CHSA). CHSA is a designated member and majority owner of the LLP. HMRC also suspect that CHSA are involved in moving Users to a further set of arrangements which involve the acquisition of their PSC.

Purity Ltd

Details of persons suspected of promoting the scheme, or of being a connected person Purity Ltd / Rebecca Waterfield (Director of Purity Ltd)
Address of person suspected of promoting the scheme 85 Great Portland Street, London, W1W 7LT
Date of publication 25 January 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work Purity Ltd (‘Purity’) employees provide their services to an end client via a recruitment agency. The recruitment agency pays Purity for the work done by the employees. Purity then makes two payments to the employees. The first payment, a salary at the National Minimum Wage or National Living Wage rate, described on bank statements as ‘Purity Salary’ is made with Income Tax and National Insurance contributions (NICs) deducted. The second payment, described on bank statements as ‘Purity Adv’ is made without Income Tax and NICs deducted.
Any other information HMRC considers relevant to publish about these schemes HMRC’s position is that the untaxed payment described on bank statements as ‘Purity Adv’ is normal income, and Income Tax and NICs are payable on it. HMRC have previously published Spotlight 60 information about the tax avoidance arrangements used by some 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 of Purity to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Purple Pay Limited

Name of promoter Purple Pay Limited
Date arrangements subject to Stop Notice published 13 April 2023
Date name of promoter subject to Stop Notice published 7 December 2023
POTAS publication List of tax avoidance schemes subject to a stop notice

Rainbowpay Ltd

Details of persons suspected of promoting the scheme, or of being a connected person, or having any other role in relation to making the scheme available for implementation Rainbowpay Ltd / Lyndsey Pauline Scott (Director of Rainbowpay Ltd) / Sunil Lekhi (former Director of Rainbowpay) / Flexen Ltd (Incorporated in Cyprus) / Giannakis Fysentzou (Director of Flexen Ltd and counter signatory to the Annuity Agreements)
Addresses of persons suspected of promoting the scheme, or having any other role in relation to making the scheme available for implementation Rainbowpay Ltd: 40 Caversham Road, Reading, RG1 7EB / Flexen Ltd: Stratigou Timagia, 15 Linda Court, 3rd Floor 6051, Larnaca, Cyprus
Date of publication 1 December 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The arrangements involve individuals providing their services to end clients or agencies through Rainbowpay Ltd who operate the payroll. The individuals also enter into an agreement with Flexen Ltd where individuals grant Flexen Ltd the option to enter an Annuity Agreement in exchange for payments (the ‘Grantee Payments’). The individuals receive a payslip from Rainbowpay Ltd showing Income and Deductions including tax and National Insurance contributions (NICs). This amount is subsequently reported to HMRC. However, the amount actually paid into the individual’s bank account is greater than the amount shown on the payslip and the difference between these two amounts has not been subjected to tax or NIC. It is HMRC’s view that the amount paid without tax and NIC deductions represents the ‘Grantee Payments’ but paid by Rainbowpay Ltd on behalf of Flexen Ltd. It is also HMRC’s view that the ‘Grantee Payments’ are also income for the services provided by individuals through Rainbowpay Ltd, and therefore the entire payment should be subject to tax and NIC deductions.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlight 60 guidance on agency workers and contractors employed by umbrella companies.

React Administration Services Limited

Details of persons suspected of promoting the scheme, or of being a connected person React Administration Services Limited (RASL) / Kevin Taylor (Director of RASL)
Addresses of persons suspected of promoting the scheme 2 Brunel Way, Slough, SL1 1XL
Date of publication 29 February 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The scheme user enters an employment contract with React Administration Services Limited (RASL) and provides their services to an end client. RASL then makes a single payment to the scheme user for their services, but this is artificially separated into two elements. The first element is a salary paid at or around National Minimum Wage or National Living Wage with tax and National Insurance contributions (NICs) deducted. The secondary element is described as a ‘propelled payment’ with no tax and NICs deducted.
Any other information HMRC considers relevant to publish about these schemes 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 tax and NICs. HMRC have previously published Spotlight 60 guidance 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 of RASL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Resource Hubco Limited

Details of persons suspected of promoting the scheme, or of being a connected person Resource Hubco Limited (RHL) /  Cornelia Van-Der-Sluis (Director of RHL)
Addresses of promoters suspected of promoting the scheme 3 Piccadilly Place, Manchester, M1 3BN
Date of publication 28 June 2023
Legislation under which this scheme/promoter has been named  Finance Act 2022
How the scheme is claimed to work  The scheme user enters an employment contract with RHL who make composite payments to the scheme users for services provided by the user. The first element is a National Minimum Wage/living wage salary that is subjected to tax and National Insurance contributions, and a secondary element described as an ‘advance drawn down’ which is not.
Any other information HMRC considers relevant to publish about these schemes HMRC’s view is that these payments are actually no different to normal income, and tax and National Insurance contributions are payable. HMRC have previously published Spotlight 60 information about the tax avoidance arrangements used by some umbrella companies. HMRC are aware that some Umbrella Companies operate more than one scheme, eg a standard compliant scheme and a non-compliant scheme. HMRC advise employees of RHL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Saxonside Limited

We have published 2 entries that relate to schemes operated by Saxonside Limited:

  • Saxonside Option Grant – Published under Promoters of Tax Avoidance regime
  • Saxonside Share Growth – Published under Finance Act 2022

Saxonside Limited – Saxonside Option Grant

Name of promoter  Saxonside Limited (SAX)
Legislation under which this Stop Notice has been published  Promoters of Tax Avoidance Schemes (POTAS)
Date arrangements subject to Stop Notice published   2 March 2023
Date name of promoter subject to Stop Notice published     7 June 2023
POTAS publication List of tax avoidance schemes subject to a stop notice

Saxonside Limited – Saxonside Share Growth

Name of scheme Saxonside Share Growth
Details of persons suspected of promoting the scheme, or of being a connected person Saxonside Limited (SAX), Omni Contractors PCC Limited (OCP), Adam Fathers (director of SAX), Kirsty LeMarechal (former director of OCP)
Addresses of promoters suspected of promoting the scheme Saxonside Limited: Centaur House, Ancells Road, Fleet GU51 2UJ / Omni Contractors PCC Limited: Unit 2 Close Beg, Peel, Isle of Man IM5 1XF
Date of publication 31 August 2022
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary The scheme users enter into an employment contract with SAX and receive a share in OCP, a separate, protected cell company. The share is unique to the scheme user’s name. SAX pay the scheme user a National Minimum Wage (NMW) salary through the payroll and OCP makes an additional payment that is allegedly for the growth in the share’s value. This is paid without Income Tax and National Insurance contributions (NICs) deductions. SAX alleges that the payment will later be subject to capital gains tax (CGT), and they retain an amount that they will allegedly release back to scheme users to cover any future CGT liability. Scheme users retain around 71 to 73% of the expected gross contract value. Read more detail about how this scheme operates.

SmartPay Limited

Name of scheme SmartPay Third Party Loan
Name of promoter or supplier of scheme SmartPay Limited (Incorporated in the Isle of Man) (SmartPay (IOM)) / SmartPay Limited (Incorporated in the UK) (SmartPay (UK))
Address of promoter or supplier of scheme SmartPay Limited, 3A Samuel Harris House, 5-11 St Georges Street, Douglas, Isle of Man, IM1 1AJ / SmartPay Limited, Blackpool Technology Management Centre, Faraday Way, Blackpool, Lancashire, FY2 0JW
Date of publication 24 August 2023
Scheme Reference Number (SRN) 62482307
Date SRN allocated to the scheme 23 June 2022
Legislation under which this scheme/promoter has been named Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work – summary SmartPay (IOM) signs an employment agreement with the scheme user and a contract for services with SmartPay (UK). The user also enters into a ‘facility agreement’ with Smartpay (IOM), acting as trustee for a related trust whereby the user is provided with a loan facility. SmartPay (UK) then enters a contract for services with a recruitment agency for the user’s services. The recruitment agency then enters a contract for services with the end client. The end client pays the recruitment agency for the scheme user’s services, who in turn pay SmartPay (UK). Following the deduction of a fee, SmartPay (UK) pay the remaining amount to SmartPay (IOM). SmartPay (IOM) pays a salary in line with the National Minimum Wage Act to the scheme user and a payment described as a loan which is made without deductions of Income Tax or National Insurance contributions.
Judicial rulings relating to the scheme  HMRC v SmartPay Ltd [2022] UKFTT 146

Solucionis Ltd

Details of persons suspected of promoting the scheme Solucionis Ltd (“Solucionis”)
Addresses of persons suspected of promoting the scheme Horton House, Exchange Flags, Liverpool, England, L2 3PF
Date of Publication 25 April 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The remuneration for the scheme users’ services is artificially separated into two elements. The first is a salary with tax and National Insurance (NICs) deducted. The second is purported to be either for the growth in a share in an Isle of Man cell company, or for an option grant, with no tax and NICs deducted
Any other information HMRC considers relevant to publish about these schemes HMRC’s view is that these payments are actually no different to normal income, and tax and National Insurance contributions are payable. HMRC have previously published information on Umbrella companies offering to increase your take home pay (Spotlight 45).  HMRC are aware that some umbrella companies operate more than one scheme, e.g. a standard compliant scheme and one or more non-compliant schemes. HMRC advise employees of Solucionis to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

Ultra Employment Ltd

Details of persons suspected of promoting the scheme, or of being a connected person Ultra Employment Ltd (UEL) / Mr Barry Aldridge (Director of UEL)
Addresses of persons suspected of promoting the scheme 3rd Floor, 5 Temple Square, Temple Street, Liverpool, L2 5RH
Date of Publication 11 April 2024
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work The scheme users enter an employment contract with UEL and receive their remuneration by one of three payment methods, all of which mean tax and National Insurance contributions (NICs) are only paid on part of the entire remuneration for the user’s services. The first method is a single aggregated payment from UEL, made up of two elements, a salary with tax and NICs deducted, and another without deductions. The second method involves two separate payments to the scheme user from UEL, a salary with tax and NICs deducted, and another made without deductions. The third method is a salary paid by UEL, with the other payment made by a third party. UEL purport that the untaxed amounts are for either a share growth in an Isle of Man cell company, or other means that they maintain is not related to employment income.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published Spotlights on Disguised remuneration schemes involving umbrella companies (Spotlight 45 and Spotlight 60) based on similar arrangements. HMRC are aware that some Umbrella Companies operate more than one scheme, such as a standard compliant scheme and a non-compliant scheme. HMRC advise employees of UEL to familiarise themselves with the guidance and to satisfy themselves that the correct amount of tax is being deducted on their income.

The Umbrella Agency Limited

Name of scheme The Umbrella Agency Annuity Option Scheme
Details of persons suspected of promoting the scheme, or of being a connected person The Umbrella Agency Limited (TUA) / Stuart John Brooke (director of The Umbrella Agency Limited) / Griffith Anderson Limited
Addresses of promoters suspected of promoting the scheme The Umbrella Agency Limited: The Colmore Building 20 Colmore Circus, Queensway, Birmingham, England, B4 6AT / Griffith Anderson Limited: 7 Bell Yard, London, England, WC2A 2JR
Date of publication 31 August 2022
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary The arrangements involve individuals providing their services to end clients through TUA and entering into an agreement that sees the individual grant TUA an option on an Annuity Agreement. The result is the remuneration for their services is artificially separated into salary as well as payments said to be in return for the option. The payments in relation to the annuity option are not subjected to tax and National Insurance contributions.
Any other information HMRC considers relevant to publish about these schemes The Scheme Reference Number 05565111 was allocated to the arrangements on 3 August 2022. The employing company, TUA, states that it simply acts as a payroll bureau and agent for another company based in Malta under the ultimate direction of the same director as the employing company.

Veqta Ltd

Name of scheme Veqta Remuneration Structure
Details of persons suspected of promoting the scheme, or of being a connected person Veqta Ltd (Incorporated in Malta) – Offshore Promoter / Stuart John Brooke (Director of Veqta Ltd (Malta)) / Veqta Ltd (UK) – Onshore Intermediary
Addresses of promoters suspected of promoting the scheme Veqta Ltd (Malta), 1, Floor 2, Falzun Street, C/W Naxxar Road, Birkirkara, BKR1441, Malta / Veqta Ltd (UK), 20-22 Wenlock Road, London, N1 7GU
Date of publication 5 July 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary Scheme users provide services to end clients through Veqta Ltd (a Maltese company) and its UK nominee and agent. The users enter into an agreement that grants Veqta Ltd (Malta) an option on an annuity agreement. The remuneration for their services is artificially separated into salary and payments said to be in return for the option. The payments said to be in relation to the annuity option are made without the deduction of Income Tax and National Insurance contributions.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published information about The Umbrella Agency Ltd, for which Stuart John Brooke is also a director. HMRC has published Spotlight 35 in 2017 on Disguised Remuneration schemes involving annuity agreements, based on a predecessor arrangement.

Vision HR Solutions Ltd

Name of scheme Vision HR Remuneration Structure
Details of persons suspected of promoting the scheme, or of being a connected person Vision HR Solutions Ltd (Incorporated in Malta) – Offshore Promoter / Stuart John Brooke (Director of Vision HR Solutions Ltd (Malta)) / Vision Human Resources Solution Ltd – UK Promoter
Addresses of promoters suspected of promoting the scheme Vision HR Solutions Ltd (Malta), 1, Floor 2, Falzun Street, C/W Naxxar Road, Birkirkara, BKR1441, Malta / Vision Human Resource Solutions Ltd, 71-75 Shelton Street, London, Greater London, WC2H 9JQ
Date of publication 5 July 2023
Legislation under which this scheme/promoter has been named Finance Act 2022
How the scheme is claimed to work – summary Scheme users provide services to end clients through Vision HR Solutions Ltd (a Maltese company) and Vision Human Resource Solutions Ltd (its UK nominee and agent). The users enter into an agreement that grants Vision HR Solutions Ltd (Malta) an option on an annuity agreement. The remuneration for their services is artificially separated into salary and payments said to be in return for the option. The payments said to be in relation to the annuity option are made without the deduction of Income Tax and National Insurance contributions.
Any other information HMRC considers relevant to publish about these schemes HMRC have previously published information about The Umbrella Agency Ltd, for which Stuart John Brooke is also a director. HMRC has published Spotlight 35 in 2017 on Disguised Remuneration schemes involving annuity agreements, based on a predecessor arrangement.

Worx 4U Limited

Name of promoter or supplier of scheme Worx 4U Limited (W4U)
Address of promoter or supplier of scheme Izabella House, Regent Place, City Centre, Birmingham, B1 3NJ
Date of publication 11 April 2024
Scheme Reference Number (SRN) 12830149
Date SRN allocated to the scheme  23 January 2024
Legislation under which this scheme/promoter has been named Disclosure of Tax Avoidance Schemes (DOTAS)
Statutory Provisions on which the tax advantage is based Section 62 Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
How the scheme is claimed to work – summary A company enters into a contract (the ‘Master Contract’) with ‘ContractingWorks’, the trading name of Worx 4U Limited (W4U), to provide consultancy services. W4U signs an agreement with the individual director of the company to undertake the consultancy services to W4U. W4U pay the individuals a flat fee per day exclusive of VAT. On the last working day of each week, the individual submits an invoice to W4U for their services. The individual then signs an advance deed, described as the ‘Self Employed Advance Deed’. This provides an initial advance against their future earnings or bonus payments of no more than £5,000 and, from time to time, such further advance payments as the company think fit. It is claimed that ‘Any advance payments shall be repayable’, but HMRC hold no evidence that these advance payments have ever repaid. W4U make the ‘advance’ payments to the individual, but without deductions for Income Tax or National Insurance contributions.

3. If you’re involved in a tax avoidance scheme

If you’re worried about becoming involved in a tax avoidance scheme, or think you’re already involved and want to get out of one, HMRC is here to help.

If you’re using any of the schemes shown on the lists or similar schemes, HMRC strongly advises you to withdraw from them and settle your tax affairs to prevent building up a large tax bill.

If you’re already speaking to someone in HMRC about your use of a tax avoidance scheme, you should contact them to discuss this further.

If you do not have an HMRC contact and you want to get out of a tax avoidance scheme, contact HMRC.

Report a tax avoidance scheme to HMRC

You can report tax avoidance schemes and those offering you the schemes to HMRC. You can do this by using the report tax fraud or avoidance online service.

You can submit this form anonymously. You do not have to give your name, address or email.

If you cannot use the online form, you can contact HMRC.

4. Details of how each named scheme is claimed to work

Countrywide Partners Limited

  1. Scheme users enter into an employment contract with Countrywide Partners Limited (CPL). The contract states that the user will be paid a salary equivalent to National Minimum Wage (NMW) or National Living Wage (NLW) plus holiday pay. It also provides that any additional payments will constitute as a ‘Bonus’.

  2. Users will also enter into a ‘Bonus, Incentive or Pay Scheme Offer’ called the ‘Bonus Agreement’ and a separate Loan Agreement with CPL. The Loan Agreement states that CPL promises to loan certain monies, secured against any ‘bonus’ payments, made to the user as pursuant to the terms of the bonus agreement.

  3. CPL invoice the recruitment agency or end user for the services carried out by the scheme user. CPL retain 15% from the gross amount received.

  4. CPL pay the user:

  • the NMW or NLW salary and any holiday pay through the payroll with Income Tax and National Insurance contributions deducted from these earnings

  • the remaining balance is paid to the user in the form of a loan (that will supposedly be repaid by future bonus payments) – bonus payments are taxable income, but tax is not paid on the loans.  

Saxonside Limited – Saxonside Share Growth

  1. The scheme users enter into an employment contract with Saxonside Limited (SAX) and are issued a share in the cell in Omni Contractors Limited (OCP) that is unique to the scheme user.

  2. Scheme users submit timesheets to SAX who then invoice the agency or end client for the work done.

  3. SAX retains approximately 10% of the invoiced amount, which is allegedly for covering any capital gains tax (CGT) the scheme user may be liable to in relation to the share. SAX claim they will return this amount to the scheme user when their CGT liability is confirmed.

  4. SAX retains a further amount of around 18% to 21% and pay the scheme user a National Minimum Wage salary.

  5. OCP pays the scheme user a separate amount without deductions for tax and National Insurance contributions. This supposedly represents the increased share value held in OCP.

5. Explanation of terms used

Accelerated Payment Notice (APN)

An APN is a requirement to pay an amount on account of tax or National Insurance contributions. HMRC issues APNs to taxpayers involved in avoidance schemes where an SRN has been allocated under the DOTAS rules, or ones in respect of which HMRC has given a General Anti-Abuse Rule counteraction notice. They can also be issued to taxpayers who have received a follower notice in relation to a scheme.

Authorised Officer

An authorised officer is a person that has been authorised by the Commissioners for HMRC for the purpose of the 2022 legislation (section 86 Finance Act 2022). Only authorised officers can authorise the publication of information under the section.

For the purposes of this legislation, authorised officers will be senior civil servants and independent of any compliance activity relating to the tax avoidance scheme in question.

Conduct notice

A conduct notice forms part of the POTAS regime. It is issued by HMRC and imposes conditions on a promoter that must be complied with.

Connected persons

For the purposes of the 2022 legislation, a person is a connected person in relation to a scheme, or to a promoter of a scheme, if the person is within one of 5 specified categories. Read more information about connected persons.

Enabler

Any person who is responsible, to any extent, for the design, management, marketing or otherwise facilitating another person to enter into abusive tax arrangements.

Entity

A business entity is an organisation created to conduct business, engage in a trade or partake in similar activities. For example, a ‘partnership’, ‘company’ or ‘limited liability partnership’.

Follower Notice

A follower notice can be given to a person who has used an avoidance scheme that has been shown in another person’s litigation to be ineffective. The follower notice tells the person they may be liable to a penalty of up to 30% of the tax and/or NICs in dispute if they do not amend their return or settle their dispute.

Promoter

A person is a promoter if they are carrying on a business that includes, or has included, the design, marketing, implementation, organisation or management of tax avoidance schemes. A ‘person’ could be an individual, company or partnership.

Scheme reference number (SRN)

A SRN is a number allocated to a tax avoidance scheme by HMRC at the time the scheme is disclosed to them, or, where a scheme has not been disclosed and HMRC reasonably suspect that the scheme should have been disclosed. It allows HMRC to identify and track users of disclosed tax avoidance schemes. The allocation of a SRN does not mean that HMRC has in any way approved or cleared a scheme for use.

Stop Notice

Stop notices may be issued to a person who HMRC suspects is promoting an avoidance scheme, which they consider does not work. If a promoter does not comply with a stop notice they would meet a POTAS threshold condition. This may lead to HMRC giving them a conduct notice.

Monitoring notice

A monitoring notice forms part of the POTAS regime. It is issued by HMRC where a promoter breaches a requirement in a conduct notice. A promoter that is subject to a monitoring notice is referred to as a monitored promoter and is subject to various disclosure requirements and other obligations and a strict penalty regime where those requirements or obligations are not met.

Supplier

Supplier refers to persons involved in the supply of tax avoidance schemes. ‘Supplier’ includes promoters and also other suppliers who do not meet the definition of promoter. There are many different ways a person may be involved in the supply of the scheme.

Back to top