HMRC v AML Tax (UK) Ltd and another

In HMRC v AML Tax (UK) Ltd and another [2022] UKFTT 174 (TC) (4 May 2022) the FTT granted HMRC’s application under the DOTAS rules holding that a ‘split contract’ scheme constituted notifiable arrangements and that AML was a promoter of those arrangements.

Under the scheme one or more directors of a user company would differentiate their fiduciary duties as director from their other duties. The director duties would be remunerated by a nominal salary but the remaining duties (called consultancy services) would be provided via an Isle of Man resident company AML Contracts. The user company would enter into a contract with AML Contracts who would provide the services of the director on a self-employed basis. The director would be paid a small retainer for consultancy services and would receive an unsecured loan from an Isle of Man trust.

In determining whether the arrangements were notifiable...

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