Stop notice 38

Arrangement details

The remuneration received by users that is attributable to the services provided by them to end clients/agencies is artificially separated by Company X into 2 elements. One of those elements is paid as a salary that is subjected to Income Tax and National Insurance contributions (NICs) viaPAYE, the other is claimed not to count as employment income and is paid in another manner that is not subjected to Income Tax andNICs. This secondary element is paid by virtue of a conditional annuity purchase agreement, 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.