Countrywide Partners Limited - HMRC named tax avoidance scheme

Countrywide Partners Limited

  • Promotor of Scheme: Countrywide Partners Limited (CPL)
  • Address: Suite 114, 25 Goodlass Road, Liverpool L24 9HJ
  • Publication Date: 4 August 2022
  • Scheme Reference Number (SRN) and date it was allocated: 20980718, 18 April 2022
  • HMRC’s Scheme Description: “Countrywide Partners Limited (CPL) invoice and receive payment from the end user. CPL retain a fee of 15% of the gross amount received. CPL pay the scheme user either a National Minimum Wage (NMW) or National Living Wage (NLW) salary which is taxed under PAYE. CPL pay the remaining amount in the form of a loan. This amount is not taxed under PAYE.”

Countrywide Partners Limited – more details

The HMRC website states the scheme operates as follows:

  1. Scheme users enter into an employment contract with Countrywide Partners Limited (CPL). The contract states that the user will be paid a salary equivalent to NMW or NLW plus holiday pay. It also provides that any additional payments will constitute as a ‘Bonus’.
  2. Users will also enter into a ‘Bonus, Incentive or Pay Scheme Offer’ called the ‘Bonus Agreement’ and a separate Loan Agreement with CPL. The Loan Agreement states that CPL promises to loan certain monies, secured against any ‘bonus’ payments, made to the user as pursuant to the terms of the bonus agreement.
  3. CPL invoice the recruitment agency or end user for the services carried out by the scheme user. CPL retain 15% from the gross amount received.
  4. CPL pay the user:
    • the NMW or NLW salary and any holiday pay through the payroll with income tax and National Insurance Contributions deducted from these earnings.
    • the remaining balance is paid to the user in the form of a loan (that will supposedly be repaid by future bonus payments). Bonus payments are taxable income, but tax is not paid on the loans.

For more information, visit the following page on the government’s website: Current list of named tax avoidance schemes, promoters, enablers and suppliers.

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