A note in the group accounts for the year to 28 February 2016 reveals the company could be set to receive a bill of £25.9m from HMRC ‘including penalties’ relating to ‘certain VAT positions that have been taken by the company between 1 July 2012 and 29 February 2016’.

‘The position is currently subject to dispute between HMRC and the company,’ it said.

Separately, it revealed ‘ongoing discussions and enquiries’ with HMRC regarding related party transactions between the company and ‘certain related party companies’.

‘The nature of the enquiries are largely focused on fact gathering relating to corporate taxes,’ it said. Other than an assessment of £669k for the Diverted Profits Tax, no other assessment has been made, it said.

Last year, KPMG auditors said the company’s structures were too opaque and highlighted £134m owed to Lycamobile by related companies, with a knock-on effect that this year’s accounts still lacked sufficient information.

‘Because of the significance of the matter... we have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion,’ said KPMG in the latest accounts. ‘Accordingly we do not express an opinion on the financial statements. We were unable to determine if adequate accounting records have been kept by the parent company.’

Lycamobile UK’s own directors’ report admitted that the tax dispute and complex structure create ‘material uncertainty that may cast significant doubt on the company’s ability to continue as a going concern and therefore may be unable to continue realising its assets and discharging its liabilities in the normal course of business’.

Lycamobile UK’s Group accounts are available here.