HM Revenue & Customs has issued its first tax avoidance Stop Notices to an individual, ordering Paul Baxendale-Walker, a struck-off solicitor and former barrister, to cease promoting two schemes deemed abusive and artificial by the tax authority.
In a landmark move, HMRC confirmed that these Stop Notices mark the first time the orders have been issued to an individual rather than a company, underscoring the government’s intent to clamp down on tax avoidance regardless of how schemes are structured.
The two arrangements, promoted by Mr Baxendale-Walker, involve offshore trusts and complex structures designed to allow users to access their funds while avoiding tax. HMRC has assessed these as schemes without genuine business purpose, aimed solely at exploiting tax loopholes.
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. These Stop Notices send a clear message: we will use every tool at our disposal to protect public finances from tax avoidance.”
The notices were issued under the government’s strengthened anti-avoidance framework, which forms part of a broader strategy to close the tax gap and protect funding for vital public services.
Tax avoidance Stop Notices are formal legal orders requiring the recipient to immediately cease the promotion of specific schemes. Failure to comply can lead to significant financial penalties or even criminal prosecution.
Mr Baxendale-Walker, who has previously been the subject of legal action and enforcement proceedings related to tax avoidance, is now barred from marketing or facilitating these two specific schemes.
The schemes in question have now been added to HMRC’s list of tax avoidance arrangements subject to Stop Notices, which is available to the public on GOV.UK.
HMRC is calling on the public and professional advisers to report any continued promotion of these schemes. Anyone aware of Mr Baxendale-Walker continuing to market them is urged to contact the department via its website.
Individuals who believe they may have used a tax avoidance scheme — whether promoted by Baxendale-Walker or others — are advised to contact HMRC immediately by emailing: CAGetHelpOutOfTaxAvoidance@hmrc.gov.uk
This move represents a significant step in the government’s ongoing effort to combat aggressive tax planning and signals that individual promoters, not just companies, are now firmly in HMRC’s sights.
