Trust, Group, gone: the name that appeared beside the church on the lobbying register

The Plymouth Brethren Christian Church has been a declared client of a Westminster lobbying firm since the end of 2024. That much has been quietly on the public record for two years. What is new is the name that appeared beside it.

In the last quarter of 2025 the firm's return stopped naming the church on its own. It named “Plymouth Brethren Christian Church, GAPIP Trust” — one client, two names. Three months later GAPIP had separated into a client in its own right. Three months after that it was not declared at all.

What the register says

Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, a VAT-registered person who, in the course of a business and in return for payment, makes oral or written communications personally to a Minister of the Crown or a permanent secretary must be entered on the register kept by the Registrar of Consultant Lobbyists. Every quarter that person must file an information return naming those on whose behalf the lobbying was done, and those from whom payment was received for lobbying to be done.

Political Lobbying & Media Relations Limited, trading as PLMR, of Church House, 29 Great Smith Street, Westminster, is on that register. These are its declarations for this family of clients, across every quarter the Registrar has published.

Every quarterly return the Registrar has published, read from the Registrar's own files on 22 October 2026. “None of them” means PLMR filed a return for that quarter naming other clients, but none of these three.

Three things follow. A name arrives. The church had been a declared client on its own since the end of 2024. In the quarter to December 2025 the entry becomes one client with two names inside it.

The name separates. In the quarter to March 2026 GAPIP is no longer inside the church's entry. It is a client in its own right, listed separately from the church and from the Rapid Relief Team.

Then it goes. In the quarter to June 2026 the return names one client in this family: the church, its name misspelled as “Christan”. GAPIP is not there. Neither is the Rapid Relief Team.

The same quarter, written two ways

PLMR also declares its clients on the Public Affairs Register published by the Public Relations and Communications Association, a voluntary quarterly declaration by member agencies. For October to December 2025 the two registers match word for word: one client, “Plymouth Brethren Christian Church, GAPIP Trust”.

For January to March 2026 they do not.

A group and a trust are not the same kind of thing. Neither register gives an address for a client, and neither records what was said, to whom, or to what end. So the registers alone cannot tell a reader which GAPIP this is. For that, you have to look at where the name turns up elsewhere.

What GAPIP is on the public record

GAPIP (NZ) Limited, company number 6299520, was incorporated in New Zealand on 12 June 2017. The incorporation document was presented by Kevin Cedric Sorensen of UBT Legal Services, Onehunga, Auckland. Its registered office and its address for service are given in the same words:

A trust of that name exists, then, and a New Zealand company was registered at it. The company was incorporated with three directors holding one share each: Caleb John Hall of Palmerston North, Philip Bruce McNaughton of Beecroft, New South Wales, and Dean Athol Hales of Eastwood, New South Wales.

The filing required each director to declare any Australian directorship. McNaughton and Hales each declared the same one: GAPIP PTY LTD, ACN 616303078, registered office “UBT, Level 6, 10 Herb Elliott Drive, Sydney Olympic Park”. A second company of the same name, at the offices of UBT, the central business support operation for the church's commercial network, in the precinct raided by the Australian Taxation Office in March 2024.

Two later filings record what became of the New Zealand company. On 14 June 2024 Dean Athol Hales was removed as a shareholder and Caleb Hall's holding went from one share to two. On 17 and 18 September 2024 Hall and McNaughton signed a shareholders' special resolution under section 318 of the Companies Act 1993, asking the Registrar to remove the company from the register on the ground that it had no surplus assets.

The resolution carries its own audit trail. The signing bundle was created from an address at ubteam.com. Hall signed from an address at ubteam.com and McNaughton from one at ubtaccountants.com. The electronic signature account is in the name of UBT Accounting. UBT's lawyers incorporated it; UBT's accountants wound it up; its Australian sister company sits at UBT's front door.

The three names

We have written before about the Global Advisory Panel, known inside the church as GAP, and about the Australian company GAP Global Pty Ltd registered at the same Sydney Olympic Park precinct. On the directors list we published for 1 January 2024, all three men who incorporated GAPIP (NZ) Limited were there.

Philip McNaughton, accountant, formerly a director of UBT Accountants, whose daughter is married to Bruce Hales' eldest son. Dean Hales, second son of Bruce Hales. And Caleb Hall, who remained a director of GAP Global Pty Ltd on the list we published for 1 July 2025, after eight of the thirteen resigned in the eighteen months following the ATO raid.

The overlap is exact, and documented on both sides. These three sat on the board of the company carrying the Panel's name. These three incorporated and owned the company carrying GAPIP's.

Why it matters

The church's public position is that it has no formal hierarchy and no leadership structure. Our reporting has set against that a different picture: a panel of senior businessmen, incorporated in Australia, approving expenditure and directing a commercial network.

A company registration shows that a structure exists. A lobbying return shows something else. It shows that structure paying for professional access to British government, and it shows how the structure chose to describe itself at the moment it did so. For one quarter the church and GAPIP were a single declared client. For the next, GAPIP stood on its own, under a name written down two different ways in the same three months. For the quarter after that, it was not declared at all.

The statutory register exists because Parliament decided the public should be able to see who is paying to approach ministers. That is a question of substance for anyone asking whether this is a church with businesses attached, or a business with a church attached.