{"id":9874,"date":"2023-07-03T11:46:33","date_gmt":"2023-07-03T10:46:33","guid":{"rendered":"https:\/\/www.taxpolicy.org.uk\/?p=9874"},"modified":"2023-08-17T21:53:48","modified_gmt":"2023-08-17T20:53:48","slug":"scheme","status":"publish","type":"post","link":"https:\/\/heacham.neidles.com\/2023\/07\/03\/scheme\/","title":{"rendered":"The outrageous \u00a350m tax scheme that was KC-approved. Part 1: The Scheme."},"content":{"rendered":"\n
Many “tax avoidance schemes” are in fact just tax fraud. We have been investigating one in detail, involving a company splitting its business between 10,000 companies, and using social media to hire 10,000 Filipino individuals who it can pretend are the shareholders\/directors. <\/em><\/strong><\/p>\n\n\n\n The scheme was facilitated by an opinion from a well-known tax KC. He was surely not aware the scheme would end up being a fraud, but his opinion was in our view one that no reasonable tax lawyer should have given.<\/em><\/strong> We will be naming the KC, and publishing his opinion and our analysis, in Part 2 of this report. Part 1 introduces the scheme, how it worked, why it cost the UK at least \u00a350m, and why we believe it should be described as fraud and not tax avoidance.<\/em><\/strong><\/p>\n\n\n Elements of the scheme have been reported before, but we believe this is the first time the full picture has been put together.<\/p>\n\n\n\n Back in 2016 and 2017, Simon Goodley<\/a> at the Guardian reported on a tax avoidance scheme involving the Anderson Group.1<\/a><\/sup>Not to be confused with the Anderson Group<\/a> that’s active in construction, or Andersen LLP\/Andersen Tax<\/a> – a well-respected accounting and tax firm<\/span> Simon’s articles are here<\/a>, here<\/a> and here<\/a>, and File on Four later ran a programme<\/a> on the schemes, summarised here<\/a>. The scheme companies later went bust<\/a>, leaving HMRC out of pocket. Our founder, Dan Neidle, said at the time <\/a>that this looked more like criminal tax evasion than tax avoidance, and that is also HMRC’s view of these structures<\/a>.<\/p>\n\n\n\n Seven years on, we now have much more information on the scheme and the people running it. We know that a director of a company involved faced serious legal consequences<\/a>, and admits the scheme was a fraud. We also have a copy of the scheme opinion from a senior tax barrister\/King’s Counsel (KC) – it’s been described by other KCs as “shocking”, “appalling”, “mind-blowing” and “deeply irresponsible”. But before we go through the KC opinion, we will set out the detail of the scheme:<\/p>\n\n\n The usual kind of contracting arrangement looked like this:<\/p>\n\n\n\n This was a sensible and entirely normal arrangement, which avoided no tax.<\/p>\n\n\n At some point in 2016, unknown parties, including an outfit called the Aspire Business Partnership LLP<\/a>, and another entity (“AA”) implemented this avoidance scheme:<\/p>\n\n\n\n Then this astonishing and outrageous additional step:<\/p>\n\n\n\n It is hard to over-state just how bizarre and deeply suspicious that final step is. Our team of tax experts have worked on complicated structures for some of the largest and most complex businesses in the world. None of us have seen anything remotely like this.<\/p>\n\n\n\n Who was the end client for the scheme? The Guardian said it was the Anderson Group<\/a>.2<\/a><\/sup>Again, not to be confused with the unrelated construction group or the unrelated tax advisory group<\/span> Anderson denies that, and the CEO of Anderson continues to deny that to us today, but the Guardian report had good evidence<\/a> to the contrary, and see below for more details on the links between the companies and Anderson).<\/p>\n\n\n\n It’s important to note that there is plenty of other tax avoidance\/evasion that goes on involving mini-umbrella companies, such as paying the MUCs’ employees via loans or other arrangements which supposedly don’t attract income tax and national insurance (but really do). Or simply just deducting tax\/NI from payments to employees and then never accounting for it to HMRC. HMRC has warned about these issues here.<\/a> We are not alleging that the MUCs involved in this scheme did any of this.<\/p>\n\n\n Small companies at the time benefited from two special government incentives: a flat rate VAT scheme<\/a> (that in practice meant they got to keep about half the VAT that would normally be handed over to HMRC) and a national insurance employment allowance <\/a>(worth about \u00a33,000 at the time). AA and Contrella normally wouldn’t get either of these, because they weren’t small companies.<\/p>\n\n\n\n The intention of the scheme was that each of the 10,000 MUCs could claim the small companies’ VAT scheme and employment allowance.<\/p>\n\n\n\n We can estimate the minimum amount of tax avoided by the scheme if we assume each company has an employee for which it charges out \u00a320,000 in fees (almost certainly it would be more than that). There is then a \u00a33,000 tax benefit from the employment allowance, plus \u00a32,000 from the VAT flat rate scheme (i.e. half the 20% VAT on \u00a320,000). That’s a total of \u00a35,000 per company, across 10,000 companies – i.e. \u00a350m per year (and the companies ended up lasting about a year on average).<\/p>\n\n\n\n This is very much a minimum, because the VAT flat rate scheme qualification conditions go up to \u00a3150k per company, and so the theoretical maximum tax benefit avoided by the scheme would be if each company charged out \u00a3150,000 in fees – the total figure then is \u00a3180m.<\/p>\n\n\n\n And the 10,000 companies are the tip of the iceberg: Richard and Gillian have found<\/a> more than 55,000 other companies that look to be part of similar schemes – most likely sold by Aspire (or other promoters) to other employment agencies. That implies a total loss to HMRC of at least \u00a3300m, even on our very cautious \u00a35,000 per company estimate.<\/p>\n\n\n An obvious question is: how did they find 10,000 people in the Philippines willing to be shareholders and directors, and how did they coordinate them?<\/p>\n\n\n\n The amazing answer: by advertising on Facebook<\/a> and YouTube<\/a> to recruit Filippino directors:<\/p>\n\n\n\nThe background<\/h2>\n\n\n
The players<\/h2>\n\n\n
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The scheme<\/h2>\n\n\n
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The “avoidance”<\/h2>\n\n\n
The Filippino “directors”<\/strong><\/h2>\n\n\n