Arguable case for granting of freezing orders

HMRC suspected D Ltd of evading payment of employer National Insurance contributions. It supplied agencies with health care workers for the NHS. The NHS trusts paid the agencies which passed on to D Ltd a gross amount for each worker’s services. This amount was to cover the agencies’ commission – out of which was paid D Ltd’s commission – the worker’s net pay and their PAYE income tax and employee and employer National Insurance.

However D Ltd instead of paying the tax and National Insurance passed the amounts to an associated company E Ltd which paid more than 90% of the workers gross through personal service companies. The result was that no employer National Insurance was paid on behalf of those workers. It was possibly also the case that no PAYE or employee National Insurance was paid but HMRC was not currently pursuing that...