HMRC v IPS Progression Ltd

In HMRC v IPS Progression Ltd [2024] UKFTT 136 (TC) (12 February 2024) the First-tier Tribunal (FTT) agreed with HMRC that the respondent IPS (an umbrella company providing PAYE payroll services in respect of individuals whose personal services were made available by recruitment agencies to end users) was a promoter in relation to arrangements which involved trying to avoid income tax and NICs by treating a portion of the payments made to the employees as a loan (referred to as the ‘ILO bonus’) rather than as income and that such arrangements were notifiable because they constituted a standardised tax product. The FTT further held that IPS did not have a reasonable excuse for failing to notify the arrangements within the required deadline and set a penalty of £900 000 for that failure.

The FTT decided that the arrangements were notifiable arrangements for DOTAS because they constituted a standardised...

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