Barrister Named in HMRC Tax Avoidance Crackdown — A First for the Profession
In a landmark move, HM Revenue & Customs (HMRC) has publicly named a practising barrister as a promoter of tax avoidance schemes, the first time a member of the legal profession has been added to the government’s official list.
Setu Kamal, who has practised law for two decades, was identified by HMRC as the architect of four tax avoidance arrangements. The schemes—operated through companies including MLG Pay Limited and The Umbrella Agency Limited—promised workers they could retain more of their income by reducing or sidestepping Income Tax and National Insurance.
HMRC insists these schemes “do not work.” Instead, users risk sizeable tax bills, interest, and penalties. According to the department, Kamal’s role went beyond legal advice: he designed the underlying structures and drafted the contracts on which the schemes depended.
Breaking a Tradition of Trust
The decision to name a barrister marks a turning point in HMRC’s battle against marketed avoidance. For years, the focus has been on the companies promoting and selling schemes. By targeting the individual behind them—particularly a senior legal professional—HMRC is sending a clear message: professional status will not shield those who enable avoidance.
Jonathan Smith, HMRC’s Director of Counter Avoidance, said legal professionals carry “a position of trust and responsibility” and should not use their expertise to undermine the tax system. He urged anyone caught up in these schemes to come forward to settle their affairs.
The Rise of Umbrella Company Schemes
Many of the arrangements flagged by HMRC operate through umbrella companies, which act as intermediaries between workers and recruitment agencies. While umbrella companies can serve a legitimate role, they have increasingly been linked to schemes that disguise earnings as loans or other convoluted payments. The promise is often higher take-home pay; the reality, HMRC warns, is a bigger bill later.
Workers are being urged to scrutinise payslips for warning signs such as unusually low tax deductions or being paid in loans rather than wages. HMRC provides online tools to help workers check if their umbrella pay arrangements are above board.
What’s Coming Next
This case lands just months before sweeping reforms. From April 2026, recruitment agencies will become legally responsible for ensuring Pay As You Earn (PAYE) tax is properly accounted for on pay routed through umbrella companies. The government is also exploring tougher penalties for promoters, including new criminal offences for failing to disclose avoidance schemes and enhanced powers to pursue those controlling promoter organisations.
The move against Kamal highlights how HMRC is broadening its scope, making it clear that anyone—regardless of their standing—can face consequences for fuelling tax avoidance. With more than 170 promoters already named and a pipeline of new legislation on the horizon, the crackdown shows no signs of easing.
The full list of named tax avoidance schemes, promoters and enablers can be found on GOV.UK: Current list of named tax avoidance schemes, promoters, enablers and suppliers – GOV.UK
For workers tempted by offers of higher net pay, the message is blunt: if it looks too good to be true, it probably is.
