Previous Address — Horton House, Exchange Flags, Liverpool, L2 3PF

Arrangement details

A scheme user’s total remuneration for their contracts is separated into 2 elements. One is a salary that has Income Tax and National Insurance contributions (NICs) deducted throughPAYE. The other is paid in a manner that is claimed to not count as employment income and therefore is not subjected to Income Tax andNICsby the employer. This secondary element is paid by virtue of the purported growth of a share held by the user in an Isle of Man Protected Cell Company (PCC) and therefore not subjected to Income Tax andNICs. It isHMRC’s view that the total remuneration received by the user is attributable to the services they provide to end clients/agencies and should therefore be subjected to Income Tax andNICsin its entirety.