Countrywide Partners Limited (CPL) has lost a case at the First Tier Tribunal and has been named as a tax avoidance promoter, after it challenged HMRC’s issuance of a scheme reference number for a notifiable arrangement which promoted tax avoidance and disputed a refusal by HMRC to withdraw a stop notice.

The appellant challenged HMRC’s decision to allocate a Scheme Reference Number (SRN) to certain arrangements which HMRC considered the company should have notified under the DOTAS regime.

Countrywide Partners Limited is a PAYE payroll agency working with recruiters placing temporary medical staff, including doctors and nurses. Until 2018 the company was called IPS Progression, which was the appellant in another FTT case over tax avoidance in 2022.   In 2018 CPL was set up and Progression’s clients were transferred to CPL as ‘Progression had reached capacity’.

CPL