HMRC Publishes June 2025 Update to Named Tax Avoidance Schemes List
HMRC updated its public list of named tax avoidance schemes, promoters, enablers, and suppliers, adding four more companies suspected of operating tax arrangements involving split-pay structures. These schemes typically see workers receiving part of their income via standard PAYE salary and the remainder through alternative, untaxed means.
The list, published under the Finance Act 2022, enables HMRC to name entities it believes are involved in arrangements that do not fully comply with UK tax law — even if investigations are ongoing or no final ruling has been made.
What is the purpose of HMRC’s list?
The named tax avoidance schemes list highlights companies or individuals that HMRC believes are promoting or enabling arrangements designed to avoid Income Tax and National Insurance contributions. Inclusion on the list does not necessarily mean the arrangements are unlawful, but it signals HMRC’s concerns about possible non-compliance.
Contractors, agencies, and end clients are advised to exercise caution when engaging with any provider named and to seek independent advice if they believe they may be affected.
Who Was Named in HMRC’s June 2025 Update?
The latest update includes four companies suspected of operating split-pay structures — where workers receive part of their income through a taxed PAYE salary and the remainder through untaxed payments. While each case has specific details, HMRC believes these arrangements may fall under disguised remuneration schemes, which it continues to scrutinise.
Arrow Tree Consulting Limited
Date added: 5 June 2025
Company number: 15424716
Registered address: 85 Great Portland Street, First Floor, London, W1W 7LT
Arrow Tree Consulting is among the latest firms named by HMRC. According to official notices, workers engaged by the company receive a portion of their pay at or near the National Minimum Wage, taxed through PAYE. The remainder is allegedly paid without standard deductions for Income Tax or National Insurance. HMRC views this structure as potentially designed to reduce employment tax liabilities artificially.
Pure Employment Limited
Date added: 5 June 2025
Company number: 14910155
Registered address: 128 City Road, London, EC1V 2NX
Named individual: Stuart Ian Dutton (also known as Stuart Ian Thomas Dutton, former director)
Pure Employment Limited operates a similar model. HMRC states workers receive part of their income taxed via PAYE, while the balance is paid through alternative, untaxed mechanisms. Such arrangements have been linked to disguised remuneration schemes in previous investigations.
Head Restart Limited
Date added: 12 June 2025
Company number: 15432663
Registered address: Suite 2a, Blackthorn House, St Paul’s Square, Birmingham, B3 1RL
Named individual: Stephen Thomas Kane (Director)
Added mid-June, Head Restart Limited is suspected of employing split-pay models. HMRC notes workers receive a base wage at or near minimum rates, with additional income paid without PAYE deductions. While initially appealing, HMRC warns these schemes may result in unpaid tax liabilities that workers are responsible for.
Signature Professional Limited
Date added: 12 June 2025
Company number: 15486244
Registered address: 50 Princes Street, Ipswich, Suffolk, IP1 1RJ
Named individual: Michael David Hance (Director)
Signature Professional Limited also reportedly uses a dual-payment approach. Part of the income is processed through standard payroll, with the rest disguised as a separate, untaxed payment. HMRC highlights that such structures can raise compliance issues, especially if payslips or Key Information Documents lack transparency. Promises of unusually high take-home pay should always be treated with caution.
HMRC’s Position on Disguised Remuneration
HMRC continues to warn contractors, umbrella companies, and agencies about schemes promising increased take-home pay by avoiding PAYE. While often marketed as tax-efficient, many such arrangements are considered tax avoidance, leading to enforcement actions, including under the Loan Charge regime.
However, being named by HMRC does not automatically imply unlawful activity. Investigations may still be ongoing, and all parties are entitled to due process.
What Should Contractors and Agencies Do?
If you work with, or are considering working with, any of the companies named by HMRC, it’s essential to carefully review how you are paid. Check your payslips to understand the full breakdown of your remuneration, including any untaxed payments. Request a Key Information Document (KID) if one hasn’t been provided — this document should clearly explain your pay structure and any third-party involvement.
When in doubt, seek independent tax advice. Even if a scheme is advertised as compliant, only professional advice can help you understand the risks and your tax obligations. Remember, in many cases, individual workers bear responsibility for any unpaid taxes, not just the promoters.
Avoid umbrella companies offering unusually high take-home pay. Instead, choose providers who are transparent, compliant, and regularly audited. Companies accredited by the FCSA or certified by SafeRec meet strict standards and provide clear, PAYE-compliant payroll services with no hidden or disguised payments.
Stay Informed and Choose Compliant Providers
HMRC updates its named tax avoidance schemes list regularly. Contractors and agencies should keep up to date by reviewing the list to ensure they avoid potentially non-compliant providers. You can view the full, regularly updated list on HMRC’s official website here.
Performing due diligence on any umbrella company you work with is essential. If you want peace of mind and a compliant, transparent payroll service, consider contacting one of our Top 10 umbrella companies. We’ve carefully vetted these providers for compliance, transparency, and excellent service – so they help you stay on top of your tax obligations while maximising your take-home pay legally.
