Complex offshore tax avoidance scheme revealed

A complex tax avoidance scheme that moves income offshore has been exposed by HM Revenue and Customs (HMRC) today (29 February 2024), with anyone who has joined the arrangement warned to get out of it as soon as possible.

The scheme – linked to businessman Darren Patrick-Green – involves contractors joining Singapore registered Procorre LLP to avoid paying Income Tax and National Insurance.

These workers and their Personal Service Companies (PSCs) enter into contracts to provide services to their clients as usual.

The PSCs invoice these clients and transfer the money received to Procorre LLP.

Procorre LLP then deducts a fee before returning the rest of the income to the individuals or their PSCs. This money comprises various forms of payments including bank transfers from multiple sources and pre-paid cards.

These payments should be subject to Income Tax and National Insurance Contributions and anyone involved in this scheme should contact HMRC as soon as possible and leave the arrangement.

Darren Patrick-Green (also known as Darren Green) is the Ultimate Beneficial Owner (UBO) of Corre Holdings SA (CHSA), a Swiss-based firm which is the majority owner of Procorre LLP. CHSA is also suspected by HMRC of involvement in further arrangements, potentially including the acquisition of users’ PSCs.

Also named on GOV.UK today for being in control of Procorre LLP is Jason Bougourd and Alizeh Nanji.

Jonathan Smith, HMRC’s Director of Counter Avoidance, said:

“Tax avoidance schemes are cynically marketed as clever ways to pay less tax. The truth is they rarely work in the way the promoters claim and it is the users that can end up with unexpected tax bills.

“We would urge anyone who thinks they have entered these schemes to contact us as soon as possible to get help.”

More detail about this scheme can be found on HMRC’s list of named tax avoidance schemes, promoters, enablers and suppliers on GOV.UK. Two other schemes were also named today.

HMRC urges taxpayers to be vigilant and to stay away from tax avoidance. The Don’t Get Caught Out campaign reveals the consequences of using tax avoidance schemes which could be unexpected tax bills, interest and penalties.

If anyone has used a tax avoidance scheme promoted by any firm HMRC has named, please contact HMRC by emailing: CAGetHelpOutOfTaxAvoidance@hmrc.gov.uk

Notes to Editors

• A further two schemes and one associated individual have been named today on GOV.UK:
  1. React Administration Services Limited and Kevin Taylor
  2. Abchurch Limited
• In addition to the above, HMRC has published the DOTAS Scheme Reference Numbers for two more schemes: Apricot Umbrella Limited and ABC Umbrella Limited.
• A new criminal offence now applies to promoters of tax avoidance who fail to comply with a Stop Notice under the Promoters of Tax Avoidance Schemes (POTAS) regime in respect of tax avoidance arrangements. The legislation received Royal Assent on Thursday 22 February 2024 and came into effect immediately. This legislation also introduced a new power to allow HMRC to act more swiftly to disqualify directors of companies involved in promoting tax avoidance.
• Follow HMRC’s Press Office on Twitter @HMRCpressoffice