Stop notice 43

Arrangement details

The remuneration received by users that is attributable to the services provided by them to end clients/agencies is artificially separated by Ultra Employment Ltd 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 to not 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 the purported growth of a share held by the scheme user in an Isle of Man Protected Cell Company 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.