HMRC has issued a brace of stop notices to Baxendale-Walker ordering him to cease promoting two tax avoidance arrangements. These schemes use remuneration trusts, stop notice 49, and offshore trusts, stop notice 50.

The latter involves setting up an offshore trust, then transfers of funds through third parties back to the scheme user, then ‘the director or self-employed person claims the funds received this way are held in a fiduciary capacity’, according to HMRC.

A number of users of these schemes have lost their appeals at various tribunals recently, inlcuding individuals and partnerships.