The Chartered Institute of Payroll Professionals
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Two new names added to the tax avoidance list Published: 10 August 2023 Emailed: 16 August 2023
HM Revenue and Customs (HMRC) has updated the list of named tax avoidance schemes, promoters, enablers and suppliers.
The below schemes have been added as of 9 August 2023:
• ABC Umbrella Ltd – 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 a re additional disguised income for services provided by individuals through ABC Umbrella Limited, and the entire payment should therefore be subject to tax and NICs • IP Global Consulting Ltd (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 (NMW) amount to the user with tax and NICs deducted. IPG also makes a second payment to the user, described as an ‘advance’, without tax or NICs deducted.
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Additions to the tax avoidance list Published: 24 August 2023 Emailed: 30 August 2023
HM Revenue and Customs (HMRC) has updated the list of named tax avoidance schemes, promoters, enablers and suppliers.
The below schemes have been added as of 24 August 2023:
• Payeworx Ltd – the scheme user enters into an employment contract with Payeworx (PWL), and the scheme user’s Personal Service Company (PSC) is issued a share in Contractor Buddy PCC Limited (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 (NICs) 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 • SmartPay Limited - 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 age ncy 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 NICs.
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