HomeFWJ TakeawayTax disputesDisguised remuneration and APNsTax avoidance scheme hit list

Tax avoidance schemes currently in the spotlight are published online by HMRC as an update of its guidance notes, first published on 27 January 2014. This list comprises what it considers specific targeted examples of popular tax avoidance schemes entered into to exploit tax loopholes and mitigate the tax that would otherwise be payable.

The tax avoidance schemes currently in the spotlight will either now be subject to specific legislation since introduced or may be caught within the General Anti-Abuse rules introduced from 2013.

The current “hit list” of tax avoidance schemes in the spotlight is extensive but, looking at schemes identified by guidance issued in 2017/18, these include:

  • payments by employers to contractors for deferred annuities.
  • tax schemes seeking to avoid loan charge which commenced from 5 April 2019 as a result of the Finance Acts 2017.
  • tax schemes seeking to avoid income tax charges to contractors via job boards, where the contractor receives loyalty points which can then be cashed in with the employer.
  • VAT supply splitting – where VAT payments are reduced by splitting a supply into smaller amounts for VAT purposes.
  • re-describing loans to avoid loan charges, which may be more common within close companies.
  • misleading advertising promoting tax avoidance schemes.
  • the supreme court decision on the employee benefit trust used by Rangers Football Club.

You should always ensure that you always seek advice from a qualified tax advisor.


At Francis Wilks & Jones we have considerable experience of negotiations with HMRC, accelerated payment notices, personal liability notices, VAT security appeals to tax tribunals claims by liquidators and director disqualification claims. Please call any member of our tax disputes team now for help

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