Annex 1 - data on use of disguised remuneration
Updated 11 May 2022
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This publication is available at https://www.gov.uk/government/publications/tax-compliance-of-hmrc-suppliers/annex-1-data-on-use-of-disguised-remuneration
Please note that all individuals referred to in the following table are subject to the same tax compliance action by HMRC in respect of their use of a DR scheme as any other taxpayer who used a DR scheme.
| Date | Finding | Action taken as engager |
|---|---|---|
| November 2018 | Following analysis in November 2017 and November 2018, HMRC is aware of 5 contractors (2 contingent workers and 3 contractors who worked for one of HMRC’s suppliers) who had provided services to HMRC/RCDTS, who had a non-concurrent history of using disguised remuneration schemes. | None as DR usage was neither current, nor related to their work for HMRC. |
| November 2019 | Analysis identified 5 contingent workers whose use of a DR scheme was concurrent with the time period of their engagement by HMRC/RCDTS. | Four contingent worker engagements which were ongoing were terminated within 2 weeks of discovery. 1 contingent worker engagement had already ended at the point of identification. |
| April 2020 | Analysis identified 5 contingent workers whose use of a DR scheme was concurrent with the time period of the provision of services to HMRC/RCDTS. | All 5 contingent worker engagements were terminated within 2 weeks of discovery. |
| April 2020 | Analysis identified 2 contingent workers whose use of a DR scheme had been concurrent with a period of their engagement with HMRC/RCDTS, but who were not using DR at that time. | The 2 contingent worker engagements were not terminated. |
| July 2020 | A contingent worker was identified as using a DR scheme. | The contingent worker engagement was terminated within 2 weeks of discovery. |
| October 2020 | Analysis of HMRC’s full population of contingent workers identified no current usage of a DR scheme. | None. |
| October 2020 | Further analysis of the 5 contractors identified in November 2018, using updated compliance information, showed that for 2 service contractors their usage of DR was concurrent with the period when they provided services to HMRC/RCDTS. | The contractors were no longer providing services to the department at the time of discovery. |
| January 2021 | Analysis of HMRC’s full population of contingent workers identified no current usage of a DR scheme. | None. |
| May 2021 | Analysis of HMRC’s full population of contingent workers identified no current usage of a DR scheme. | None. |
| September 2021 | Analysis of HMRC’s full population of contingent workers identified no current usage of a DR scheme. | None. |
| November 2021 | Analysis of HMRC’s full population of contingent workers identified no current usage of a DR scheme. | None. |
| April 2022 | Analysis of HMRC’s full population of contingent workers identified no current usage of a DR scheme. | None. |
Note: HMRC does not view prior use of DR, or having sent an individual an educational letter advising them of the risks of tax avoidance, as suitable grounds to end an engagement or take someone off HMRC work. During the course of our analysis, we may discover contingent workers who are prior users of DR schemes. In these cases, no action has been taken.
HMRC is aware of 12 contractors who were in DR schemes prior to their engagement but were not using DR during their engagement by HMRC. Three of these 12 are included in the table above.