HMRC threatens individual with Stop Notice

In the first Stop Notices case of its kind, HMRC has threatened an individual with prosecution if they promote tax avoidance schemes.
A struck-off solicitor and former barrister has been ordered to stop promoting two tax avoidance schemes or face penalties or criminal prosecution if he fails to comply, HM Revenue & Customs (HMRC) announced today [15 May 2025].
Paul Baxendale-Walker must now cease promoting these arrangements after HMRC issued Stop Notices to him.
This marks the first time Stop Notices have been issued to an individual rather than to a company promoting tax avoidance schemes, HMRC said. The action “demonstrates HMRC’s commitment to use all available powers, regardless of how promoters structure their operations”, to shut down such schemes, the organisation said.
HMRC considers both schemes covered by the Stop Notices promoted by Baxendale-Walker to involve artificial arrangements, including the use of offshore trusts, designed to claim tax deductions without genuine business purpose. The schemes create complex structures to ensure money remains available to the users while claiming to avoid the tax due.
Jonathan Smith, HMRC’s director of counter avoidance, said: “The courts have already concluded that (Mr) Baxendale-Walker designed and sold multiple tax avoidance schemes that don’t work as claimed, and now these Stop Notices send a clear message that we’ll use every tool at our disposal to protect public finances from tax avoidance schemes.”
HMRC added: “Anyone who becomes aware of (Mr) Baxendale-Walker continuing to market these schemes, is asked to contact HMRC on GOV.UK.”
Anyone who thinks they may have used a tax avoidance scheme should contact HMRC as soon as possible by emailing: [email protected]
Stop Notices are issued under the Promoters of Tax Avoidance Schemes (POTAS) legislation. They require promoters to immediately cease promoting specified tax avoidance schemes, notify their clients that a Stop Notice has been issued and make quarterly compliance declarations to HMRC.
A new criminal offence for promoters who fail to comply with Stop Notices was introduced through legislation that received Royal Assent on 22 February 2024. This legislation also introduced new powers allowing HMRC to act more swiftly to disqualify directors of companies involved in promoting tax avoidance.
The government has announced further measures to tackle tax avoidance, including a strengthened HMRC reward scheme for informants targeting serious non-compliance, changes to umbrella company regulations from April 2026 and changes to tax rules on liquidations of Limited Liability Partnerships came into effect in October.
As of 15 May 2025, HMRC has published the arrangements of 155 tax avoidance schemes, named 150 promoters including 32 promoters subject to a Stop Notice.
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