Marquee Limited is an Uxbridge based agency, set up in 2018, with a sole director Mark Clarkson and no staff.

HMRC said that the arrangements involved users providing their services to end clients through Marquee Limited (ML).

The users had to sign an option grant agreement under which Marquee makes payments to users and in turn they grant the right to the agency to enter into an annuity agreement.

As a result the remuneration for their services is artificially separated into a salary and payments made under the option grant agreement said to be in return for the option.

No tax or National Insurance contributions are deducted in relation to the payments made under the option agreement.