HMRC Tax Avoidance Lists UK 2026/27 — SRNs and Red Flags

If a promoter says an arrangement can turn ordinary pay or business income into tax-free or lightly taxed money, check it before signing. HMRC publishes information about named tax avoidance schemes, promoters, enablers and suppliers, and it also explains the Disclosure of Tax Avoidance Schemes (DOTAS) rules.

The important limitation is that the list is not complete. If a scheme or promoter does not appear on the list, that does not mean HMRC approves it or that it works. The list is one risk check, not a substitute for understanding the arrangement and obtaining independent advice.

This guide explains what to look for, how scheme reference numbers work and what to do if you have already entered an arrangement. It is not a view on any named person or scheme.

What the HMRC tax avoidance list tells you

HMRC can publish information under the Finance Act 2022 publishing rules and under regimes including POTAS (Promoters of Tax Avoidance Schemes), DOTAS and the rules for enablers of tax avoidance. The published material can identify a promoter or supplier, describe an arrangement, and record action such as a stop notice.

The page can change as information is added or removed. HMRC also says that there are schemes and promoters it cannot publish information about at that time. Treat the live page as a warning and due-diligence resource, not as a complete database of lawful and unlawful arrangements.

The difference between a scheme, a promoter and an enabler

These terms describe different parts of the supply chain:

The label used by a salesperson is not decisive. Calling a payment a loan, grant, advance, capital receipt or expense does not determine its tax treatment. The legal documents, actual money movements, employment or trading relationship and purpose of the arrangement all matter.

How SRNs and PRNs fit into the process

Under DOTAS, a promoter that designs, markets or organises a notifiable scheme may have to tell HMRC within 5 working days of the relevant trigger. If a scheme is disclosed, HMRC can issue a Scheme Reference Number (SRN). The five-working-day rule is a promoter obligation; it is not a promise that a taxpayer has five working days to decide whether to join.

If you are given an SRN, do not assume it means HMRC has approved the arrangement. HMRC's guidance explains that a reference number identifies a scheme for reporting and does not confirm that the claimed tax advantage is available. Depending on the arrangement, the reference number may need to be included on a tax return or specified form. Failing to report it can create a penalty risk.

A promoter may instead use or provide a Promoter Reference Number (PRN) in circumstances covered by the applicable rules. Ask what the number identifies, where it must be reported and which official HMRC guidance supports that answer. Keep the form, message or letter that supplied the number.

Red flags before you sign

Pause and obtain independent advice if a proposal:

• promises that ordinary employment income will become tax-free or almost tax-free;
• says HMRC cannot challenge the arrangement because a reference number has been issued;
• relies on a short deadline, referral bonus or pressure to sign immediately;
• describes a complicated loan, trust, offshore payment or artificial expense without explaining the commercial reason;
• refuses to give you the full legal documents, fee terms, exit costs and tax-risk explanation; or
• tells you to use a tax return entry that does not match the money you actually received.

An arrangement can be risky even when it is not yet on HMRC's list. A list search should happen alongside document review and independent professional advice, not after the payment has been made.

If you have already joined an arrangement

Do not destroy documents, stop keeping records or automatically amend a return. Collect contracts, payslips, invoices, bank statements, promotional material, fee invoices, reference-number forms and messages from the promoter. Record the dates and amounts actually paid, not only the labels used in the paperwork.

Check whether the arrangement has a reference-number reporting requirement and whether previous returns used the correct entries. If HMRC contacts you, read the notice carefully and obtain advice before replying where the facts are complex. A promoter's assurance that the scheme is “HMRC-proof” is not evidence that the return is correct.

If you are an employee using an umbrella or intermediary, compare the total remuneration with the amount shown as taxable pay and National Insurance earnings. The strengthened reward scheme guide covers a separate current issue involving reward structures; it does not determine the tax treatment of every avoidance arrangement. If an employer or agency has withheld the wrong amount, use the Self Assessment filing guide for filing context and seek case-specific help.

Tax avoidance is not the same as ordinary tax planning

Using an available allowance, relief or pension contribution for its stated purpose is not automatically tax avoidance. The difficult cases are arrangements marketed mainly for a tax advantage where the legal steps do not match a genuine commercial or personal transaction. Whether a particular arrangement is challenged depends on the legislation, anti-avoidance rules, case law and facts.

Do not use this page to label another taxpayer, employer or adviser. Use it to identify questions that need answering before you enter an arrangement or file a return. Where the arrangement involves employment income, an umbrella company, a company director role, offshore transactions or a previous disclosure, an adviser should review the complete record.

What a list search can and cannot prove

Search the live HMRC page by the exact scheme name, promoter name, supplier name and reference number, including spelling variations shown in the documents. Record the date of the search and save the page or entry used. A scheme can be described differently in marketing material, and the absence of a match may reflect timing, publication limits or a different name rather than a positive clearance. A match is a warning that should be investigated; it is not a substitute for reading the stop notice, reporting instruction or applicable legislation.

Also distinguish an HMRC list from a tax investigation result. A named scheme may be published because HMRC has statutory publication powers, but publication does not give a taxpayer a complete calculation of the tax due or tell an adviser exactly how the arrangement was used in a particular case. Conversely, a scheme not named may still be challenged under the ordinary tax rules, the General Anti-Abuse Rule or another anti-avoidance provision. Keep the legal analysis tied to the actual transactions and money flows.

If a reference number appears on a return

Do not place an SRN or PRN in an arbitrary notes box or omit it because the promoter says the number is “for HMRC only”. Read the current return notes and the official DOTAS or promoter guidance to identify the correct field, form and tax year. A reference number is not a calculation of tax and should not be used to justify entering an amount that was not received or earned. Reconcile the return to payslips, invoices, bank statements and the contract before submitting.

If a return has already been filed, preserve the original version and ask an independent adviser whether an amendment, disclosure or correspondence is required. Do not delete a reference number or rewrite the transaction history without a documented basis. HMRC may ask for the arrangement documents, and a complete contemporaneous record is safer than a reconstructed explanation based on a promoter's summary.

Tax avoidance and tax evasion are not interchangeable labels. Avoidance generally refers to arrangements intended to obtain a tax advantage, while evasion involves dishonest concealment or false information. Both can create serious consequences, but the response should describe the facts rather than use a label as a conclusion. If you suspect fraud, obtain advice and use the official HMRC reporting or disclosure route; do not accuse a supplier publicly or circulate another person's personal details.

Keep a dated due-diligence file with the list search, promoter documents, fee schedule, contract, money-flow diagram, independent advice and any HMRC reference. Recheck the live list before filing because names, descriptions and publication dates can change. A saved search supports the process, but it does not turn a non-listed arrangement into HMRC clearance.

Frequently Asked Questions

Read HMRC's named tax avoidance scheme information and DOTAS guidance before committing to an arrangement. For ordinary filing context, see the Self Assessment filing guide and HMRC penalties and appeals guide.

Official sources

• HMRC: Named tax avoidance schemes, promoters, enablers and suppliers
• HMRC: Information it may publish about tax avoidance schemes
• HMRC: Disclosure of Tax Avoidance Schemes guidance
• HMRC: Current list of named tax avoidance schemes, promoters, enablers and suppliers