The three companies are:

Goldfish Umbrella Ltd: Scheme users enter into a contract of employment with GUL, providing services to end clients. GUL invoices the end clients for the work and, after retaining a portion of that invoiced amount, GUL will make a single payment to the scheme users made up of two elements. 

The first element is salary made at National Minimum Wage/National Living Wage with Income Tax and National Insurance contributions (NICs) deducted. The second element is described as an ‘Advance Payment’ and is made without Income Tax and NICs deducted. The total payment is more than the scheme users would have received if they were paid their salary with Income Tax and NICs correctly deducted on the full amount.

Signature Vintage Ltd: Signature Vintage Ltd (SVL) employees provide their services to an end client via a recruitment agency. The recruitment agency pays SVL for the work carried out by the employees. SVL makes a single payment to the employees each week. 

Part of the payment is salary at a rate close to the NMW with Income Tax and NICs deducted, and the remaining balance is allegedly for an ‘Option Granted’, which is paid to the employees without deductions for Income Tax and NICs.

We Are Ava Ltd, previously known as Hunter State Ltd: Hunter State, now trading as We Are Ava (WAA), provides employment to scheme users. WAA pay scheme users a salary close to the NMW or NLW rate with Income Tax and NICs deducted. 

Scheme users also receive a secondary payment from WAA described as ‘Option’ or ‘additional’ amount that is paid without Income Tax and NICs deducted. This secondary payment is typically paid on the same day as the salary payments. It is HMRC’s view that all payments made to the scheme users are taxable.

• Comment below on this story. Or let us know what you think by emailing us at [email protected] or tweet us to tell us your thoughts or share this story with a friend.