https://forums.contractoruk.com/ en Wed, 29 Apr 2026 08:13:07 GMT vBulletin 60 images/misc/rss.png https://forums.contractoruk.com/ https://forums.contractoruk.com/hmrc-scheme-enquiries/151185-west-28th-street-limited.html Sat, 25 Apr 2026 12:37:40 GMT HMRC Scheme Enquiries Wtaf https://forums.contractoruk.com/hmrc-scheme-enquiries/151185-west-28th-street-limited.html https://forums.contractoruk.com/hmrc-scheme-enquiries/151166-inside-ir35-psc-fee-payer-with-protected-cell-company-co-op-dividend-route.html Fri, 10 Apr 2026 20:32:58 GMT Hi all, I’m a PSC contractor on a long-term inside-IR35 assignment. Instead of going full umbrella, the agency is using a fee-payer who runs deemed-employment PAYE/NIC only on a base daily rate. The surplus (the difference between what the end client is actually paying and that base rate) is... Hi all,

I’m a PSC contractor on a long-term inside-IR35 assignment. Instead of going full umbrella, the agency is using a fee-payer who runs deemed-employment PAYE/NIC only on a base daily rate. The surplus (the difference between what the end client is actually paying and that base rate) is then invoiced by my limited company to a protected cell company / contractors’ co-op.

The cell company pays the money back to my PSC as dividend distributions. These dividends are not 1:1 each week – some weeks I get noticeably more back, some weeks less, but over a few months it comes back very close to 100%. The co-op’s marketing says the dividends are “not attached to my earnings” and should be treated as normal dividend income in my company accounts (no CT, no VAT).

I’ve read that HMRC has successfully challenged similar co-op / cell-company / discretionary dividend structures in the past under disguised remuneration rules. I’m starting to feel a bit uneasy about the long-term risk, especially if there’s ever an enquiry.

A few questions for anyone who’s been in (or knows of) a similar setup:

1. Has anyone actually had an HMRC enquiry on this kind of fee-payer + cell/co-op arrangement?
2. What did your accountant say when you showed them the full flow?
3. Would you stay in it or switch to a straightforward umbrella?
4. Any decent independent accountants you’d recommend who have actually reviewed these structures (not ones introduced by the provider)?

Happy to answer any questions (without naming names obviously). Just trying to get some real contractor experiences before I make any decisions.

Thanks in advance!]]> HMRC Scheme Enquiries DigitalContractor16 https://forums.contractoruk.com/hmrc-scheme-enquiries/151166-inside-ir35-psc-fee-payer-with-protected-cell-company-co-op-dividend-route.html