Last week, HMRC published a 12th “Spotlight” to do with remuneration arrangements for work carried out for UK based employers which arguably avoid income tax and NIC. A “Spotlight” is a public notice of a form of tax avoidance which has come to HMRC's attention and which they say they will challenge where it is implemented.

Per the website notice, the arrangements in question may “involve payments passing through a series of companies, loans from a third party or an offshore alleged employer, a deed of covenant, secondments from one employer company to another or claims of self-employment, etc.” HMRC state that in their opinion, these types of arrangement do not result in tax avoidance. The notice goes on to comment that there can also be adverse tax consequences where a trust vehicle is used for the purposes of tax avoidance on remuneration.

The full statement is available at www.hmrc.gov.uk/avoidance/spotlights.htm