The respondent company was a promoter of notifiable arrangements for disclosure of tax avoidance scheme (DOTAS) purposes, which had failed to comply with its notification requirements and had no reasonable excuse for that failure, and was held liable to a penalty for non-compliance of £1m. 

The respondent company (WSV) provided services to individuals who either held or were about to start a contract with an end-user or recruitment agency. Those individuals would become employed by WSV and their contracts would be assigned to WSV. The employee’s remuneration would be paid in two tranches: (1) a salary subject to PAYE; and (2) an amount paid by way of a loan on account of bonus payments. The ostensible advantage was that the employee was taxed only on the salary element and not on the loan element.;