New Off Payroll Working Rules/IR35 tool-kit and preparations for April 2020
As April 2020 (the date for implementation of the Off Payroll Working/IR35 changes) creeps closer, clients are beginning to turn their minds to their contractors and contingent workforces. We are helping a number of clients at different positions in the supply chain, whether they are end-user clients who are grappling with how to make status determinations, IT service providers trying to determine whether their client relationships are exempt, agencies and other “fee-payers”, or PSCs and contractors themselves.
We have produced a “tool-kit” for anyone preparing for the new rules.
In addition, HMRC has recently published “user guides” for end-user clients, intermediaries, agencies and fee-payers. At this stage, these guides are at a very high level. We are awaiting more detailed guidance from HMRC on matters such as what constitutes “reasonable care” in status determinations.
HMRC is currently undertaking a series of stakeholder engagement sessions and its first webinar for agents and affected organisations will be on 20 September 2019. They are also working on enhancements to the Check Employment Status for Tax (CEST) tool which will be available before the end of 2019.
In the meantime, HMRC wrote to 1,500 current and former contractors of GSK this week, claiming that they were not compliant with IR35. If the contractors dispute this, they were asked to write to HMRC by 19 September. This is a rather aggressive stance by HMRC, particularly as it seems that HMRC has not undertaken a review of each contractor’s circumstances prior to accusing them of being deemed employees. It appears to go against HMRC’s previous assurances that they would not be targeting historic cases of non-compliance in connection with the introduction of the new rules.
If you would like more information about our IR35 service, please don’t hesitate to contact one of the team.
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