The first odd thing: there two PPE Medpros. One incorporated in the UK. The other incorporated in the Isle of Man. Both Barrowman-linked companies.

Creating identically named companies isn't normal. Normal businesses go out of their way *not* to do this. It's dangerous, because it risks the names being switched by accident, e.g. on a document. I saw a case like this: it cost a large business £10m.

It's not a one-off. There are at least *seven* Barrowman companies with identically named tax haven "shadow companies" The question is: why?

It won't be tax planning or tax avoidance, for the simple reason that tax rules don't care about company names. It doesn't seem to be brand/name protection.

But we worked out why one of them has a "shadow": to trick people. We have the evidence. Barrowman's "Smartpay" company ran a tax avoidance scheme. Contractors would work for Smartpay, and Smartpay would then supply their services to recruitment agencies.

Here's the agreement between Smartpay and a contractor, and the agreement between Smartpay and a recruitment agency. Spot the difference:

The contractor was signing up with an Isle of Man company, Smartpay Ltd. The recruitment company insisted on a pukka UK company - so they were presented with the UK Smartpay Ltd. They were tricked into thinking this was an onshore business. It wasn't.

Am I being unfair? Could this just have been an accidental one-off? Nope, Smartpay Ltd *admitted* doing this in a tax tribunal. This comes very close to an admission of fraud. (Smartpay is the Respondent here)

We asked Barrowman why he operated identically named companies in different jurisdictions. We said that Smartpay's actions - admitted by them! - looked like fraud. His lawyers refused to comment. Guess why.

Was *this* why Barrowman created two PPE Medpros? To trick people into thinking they were dealing with a UK company, when they were actually dealing with an IoM company?

The second PPE Medpro mystery is: where is the money? The Guardian reported (and Barrowman does not seem to contest) that PPE Medpro made a £65m profit from its sale of £202m of PPE to the Government:

But there's no sign of any of that in PPE Medpro (UK)'s accounts:

How can a UK company make £61m of profit without it appearing in the company’s accounts and without the company paying tax on that profit? Perhaps by paying it all away to another party. That would be deeply dodgy from a tax perspective (i.e. because a chunk of the profit should

Or perhaps the UK PPE Medpro acted as undisclosed agent for other parties If so, an important consequence: a principal is generally liable for the actions of their undisclosed agent. So HMG could now recover the £122m from the principals (once they discover them)

The Government's legal advisers may already have traced what happened to the £61m of profit. If they haven't, PPE Medpro going into administration means they should be able (effectively) to get its documents.

I also expect that HMRC has open enquiries against the UK PPE Medpro, and will have issued an information notice requiring disclosure of all relevant documentation. (Although probably HMRC won't be able to share this with the Government's PPE legal team)

So I would be reasonably optimistic that the net is closing in on the £122m, from two different directions.

Our full investigation into PPE Medpro, Smartpay Ltd and Barrowman's "shadow companies" is here: https://taxpolicy.org.uk/2024/...

And you can follow me here, or subscribe for updates at https://taxpolicy.org.uk/subsc...

@DanNeidle Does the freezing of Barrowman and Mone's assets have any significance in any attempts by the Govt to recover the money?

@DanNeidle Not saying these guys did anything moral or good, but there also needs to be some liability on behalf of the procurer. What has been done by the govt to work out how they procured £122 m in products which were not fit for purpose?

@DanNeidle Considering she has just dissolved the company last night

@DanNeidle This boils my blood after being hounded by HMRC over a tax shortfall of £2k (because of my accountant’s bad practices unnoticed by me) with an £8.5k bill for interest accrued over 16years. And I earned £12k gross in that 1st yr! And these 2 face no action?? Just the company???

@DanNeidle Fantastic forensic work Dan. In the case of Smartpay, is it known what route the money took? Did the end client or agency pay the UKCO or the IOMCO, and from where were individual contractors paid?

@DanNeidle The total lack of morality here is awe inspiring, then followed by claims of victim hood. All while actual existing UK suppliers were shunned. The Conservative Party deserves to be torn apart over these frauds they facilitated.

@DanNeidle They really need to get you into the Treasury

@DanNeidle They need to be investigated by the SFO. Proceeds of crime Act to be used to recover the money.

@DanNeidle @Philmoorhouse76 They should (along with the Tory ministers who aided them) be arrested

@DanNeidle Who advises them and who comes up with such tricks within regulatory compliance oversight

@DanNeidle Possibly a case for SFO and NCA, if it leads to that.

@DanNeidle @SingleTicket371 How about putting them in jail. ? If they can for something far less then why not this?

@DanNeidle Yes, they've put it into administration!

@DanNeidle "Douglas Barrowman and Michelle Mone's company, PPE Medpro"....It wasn't "their" company, facts are important

@DanNeidle they are not the directors that i can see. how are they the owners ? where is that known ?

@DanNeidle Interesting read. Looks v dodgy indeed. Cheers.

@DanNeidle Why is she not been arrested with her partner??