[UK] HMRC will not contest £171m Ducas tax dispute

In the UK, HMRC has announced that it will not contest a £171m tax dispute involving Ducas Ltd and associated companies, ending the high-profile case weeks before it was due to be heard by the First Tier Tribunal, Contractor Calculator reports.

The dispute surrounded alleged unpaid employer National Insurance contributions for thousands of healthcare workers supplied to NHS Trusts through recruitment agencies.

The case reportedly involved Ducas Ltd, Enix Services Ltd and FL Capital Holdings Ltd. The companies were connected through common ownership and management. HMRC investigated arrangements to supply healthcare workers to NHS Trusts through recruitment agencies, with Ducas acting within the labour supply chain.

The arrangements saw NHS Trusts paying recruitment agencies a gross amount for each worker supplied. Those payments were calculated to cover net wages, PAYE income tax, employee National Insurance contributions and employer National Insurance contributions. The agencies subsequently paid Ducas for the services provided within the supply chain.

According to HMRC calculations, the arrangements involved around 30,000 workers and its estimates suggest that more than £171m in employer National Insurance contributions had not been paid. The dispute focused on how workers were ultimately paid and where liability for those tax obligations sat within the supply chain.

HMRC secured freezing orders from the High Court against Ducas, Enix Services Ltd and FL Capital Holdings Ltd in November 2024. The court reportedly accepted that HMRC had established a good arguable case and that there was a real risk assets could be dissipated before any final judgment could be enforced.

The companies appealed HMRC's assessment, and the dispute was scheduled for a 20-day hearing at the First Tier Tribunal starting in April 2026. But shortly before the hearing was due to commence, HMRC decided against contesting the Appeal.

Source: Contractor Calculator

(Link via original reporting)

In the UK, HMRC has announced that it will not contest a £171m tax dispute involving Ducas Ltd and associated companies, ending the high-profile case weeks before it was due to be heard by the First Tier Tribunal, Contractor Calculator reports.

The dispute surrounded alleged unpaid employer National Insurance contributions for thousands of healthcare workers supplied to NHS Trusts through recruitment agencies.

The case reportedly involved Ducas Ltd, Enix Services Ltd and FL Capital Holdings Ltd. The companies were connected through common ownership and management. HMRC investigated arrangements to supply healthcare workers to NHS Trusts through recruitment agencies, with Ducas acting within the labour supply chain.

The arrangements saw NHS Trusts paying recruitment agencies a gross amount for each worker supplied. Those payments were calculated to cover net wages, PAYE income tax, employee National Insurance contributions and employer National Insurance contributions. The agencies subsequently paid Ducas for the services provided within the supply chain.

According to HMRC calculations, the arrangements involved around 30,000 workers and its estimates suggest that more than £171m in employer National Insurance contributions had not been paid. The dispute focused on how workers were ultimately paid and where liability for those tax obligations sat within the supply chain.

HMRC secured freezing orders from the High Court against Ducas, Enix Services Ltd and FL Capital Holdings Ltd in November 2024. The court reportedly accepted that HMRC had established a good arguable case and that there was a real risk assets could be dissipated before any final judgment could be enforced.

The companies appealed HMRC's assessment, and the dispute was scheduled for a 20-day hearing at the First Tier Tribunal starting in April 2026. But shortly before the hearing was due to commence, HMRC decided against contesting the Appeal.

Source: Contractor Calculator

(Link via original reporting)