IR35 detailed comment


Equipment

The issue

The issues here would appear to be whether there is anything either in the contract, or in the actual relationship between Individual and Client, in relation to this factor which

·         helps towards a decision on whether that relationship, had it been direct and without a company in between, would have been an employment contract - a contract of service - or a contract for services, or

·         would be inherently inconsistent with a contract of employment.

Legal issues, and the Revenue Guidelines

Guidelines:

Provision of equipment - A self-employed contractor generally provides whatever equipment is needed to do the job (though in many trades, such as carpentry, it is common for employees, as well as self-employed workers, to provide their own hand tools). The provision of significant equipment (and/or materials) which are fundamental to the engagement is of particular importance. For example, where an IT consultant is engaged to undertake a specific piece of work and must work exclusively at home using the worker’s own computer equipment that will be a strong pointer to self-employment. But where a worker is provided with office space and computer equipment that points to employment. The fact that a worker might occasionally choose to do some of the work at home using his or her own computer does not change that (many employees do just that). (Ready Mixed Concrete (South East) Ltd v Minister of Pensions and National Insurance).[1]

The following paragraphs are extracted from the Employment Status Manual, sections ESM1061-ESM1062:  [2]

If the engager provides any necessary equipment this fact will point towards the existence of a contract of employment. A self-employed contractor generally provides his/her own equipment.

This rule of thumb is subject to exceptions. It is customary in many occupations - for example tradesmen such as carpenters - for the worker to provide hand tools, whether employed or self-employed. It is also commonplace for employees to use their own cars for the purpose of their employment. Hence little significance can be attached to the provision of small tools where it is customary for them to be provided. And is the provision of equipment necessary if the worker is "labour only"?

Provision of equipment, which is fundamental to the service provided and sufficiently important to affect the substance of the contract, is of most significance.

For example, the fact that drivers provided their own lorries was a major factor in Ready Mixed Concrete (South East) Ltd v The Minister of Pensions and National Insurance (1 968) 2QB497. The Court decided that the contracts with the company were contracts of carriage rather than contracts of employment. In R W Proffitt Ltd v Secretary of State for Social Security, television salesmen were found to be employed and one important factor in this decision was that they were supplied with cars by the employer.

But even here this factor may not be decisive on its own - particularly where it points towards employment. In Hall v Lorimer (66TC349) a vision mixer was found to be self- employed when the terms, conditions and facts surrounding his engagements were considered as a whole. This was despite the fact that the substantial and expensive equipment needed was provided by his engagers. Mummery J, in the High Court, considered that the provision of equipment by Lorimer's engagers undoubtedly pointed towards the existence of employment but this was not sufficient, by itself, to outweigh other pointers towards self-employment that were present in that particular case.

In relation to that last sentence, it has to be said that whilst Mummery J did make this statement, his decision in the case was appealed against by the Revenue, and that particular statement was not approved in the Court of Appeal - who in fact regarded it as irrelevant in the circumstances of this case that Lorimer provided no equipment.  Hall v Lorimer was the case where the Revenue

·         lost before the Special Commissioner;

·         appealed to the High Court, and lost;  and

·         appealed again to the Court of Appeal, and again lost (it appears they lacked the stomach to take the case to the House of Lords!).

It may be important to maintain a clear distinction between:

·         equipment, in the form of tools which are used to do the job - the washing machine repairman's spanner;  and

·         equipment which is the very 'object' of the services themselves - the washing machine itself

and also between

·         equipment in the form of tools belonging to the Client which is used by the Contractor purely because it is readily available and convenient to both parties for it to be used, even though the Contractor possesses and could use his own such tools;  and

·         equipment in the form of tools belonging to the Client which is expressly acquired by the Client in order to be made available for the Contractor to use, because the Contractor does not him / herself possess such tools, and

·         equipment in the form of tools belonging to the Client which are so specialised that (1) it is likely to be required from time to time by the Client for the same purpose, and (2) which if the Contractor were to acquire it, would be unlikely to be of any future use.

There are cases where provision of equipment has appeared to be an overriding factor, and has tipped the balance:

·         In Ready Mixed Concrete  [3], the provision by Individuals of their own lorries was a major factor in determining self-employment

·         In R W Proffitt Ltd v Secretary of State for Social Security  [4], television salesmen were found to be employed and one important factor in this decision was that they were supplied with cars by the employer.

In other cases it appears less material;  in WHPT Housing Ass Ltd v Secretary of State 1981 ICR 737  [5] an architect who used his own car but received a car allowance was found to be self-employed.  And in today's world, there are many undisputed employees who provide and use their own cars.

In the case of a highly skilled specialist, engaged to carry out services using the Client's own specialised equipment, the case of Hall v Lorimer is helpful:

"Mr. Lorimer provides no equipment (i.e.  he has no tools) he provides no "work place" or "workshop" where the contract is to be performed, he provides no capital for the production, he hires no staff for it.  No; he does not.  But that is not his business.  He has his office, he exploits his abilities in the market place, he bears his own financial risk which is greater than that of one who is an employee, accepting the risk of bad debts and outstanding invoices and of no or an insufficient number of engagements.  He has the opportunity of profiting from being good at being a vision mixer.  According to his reputation so there will be a demand for his services for which he will be able to charge accordingly.  The more efficient he is at running the business of providing his services the greater is his prospect of profit."

In the PCG Judicial Review case, it was said:

The Claimants are inevitably concerned that, with regard to an assignment by a software specialist at a client's premises, it would be unlikely that he would bring with him any tools or equipment, which might be one of the more obvious indicia of self-employment if, for example, he were a jobbing builder or a plumber. That must be right. However, all the aspects of the relationship must be considered.

More generally, it would seem reasonable to suggest that:

·         Use of the Client's equipment, where it is not readily available and has to be acquired specially as a tool for the Individual to carry out the services is likely to be more consistent with employment - especially where the Contractor does not him / herself possess such tools - unless the equipment is so specialised that (1) it is likely to be required from time to time by the Client for the same purpose, and (2) if the Contractor were to acquire it, would be unlikely to be of any future use.

·         Use of the Client's equipment, solely because it is readily available and its use is mutually convenient, is unlikely to be significant either way - particularly when the Contractor himself also possesses and could have used his own such tools.

·         Use of the Client's equipment, where it is the 'object' of the services, and its use is a necessary constraint given the nature of the services, is unlikely to be significant either way

·         Use of the Individual's own equipment, where it is either (1) customary for undisputed employees performing similar services to use their own equipment (eg the carpenter's tools), or (2) not of a type generally used exclusively for business, is readily available, and its use is mutually convenient, is unlikely to be significant either way.

·         Use of the Individual's own equipment, for the purposes of that Individual's business, where (1) the equipment has been specifically acquired for the purposes of the business (and generally shown in the accounts charged as a business expense), or (2) undisputed employees performing similar services would be unlikely to provide and use their own equipment, is generally likely to be more consistent with self-employment

Case law appears to suggest:

·         where major and fundamental equipment is provided, the engagement is almost certainly self-employment

·         where major but not fundamental equipment is provided, the engagement is more likely to be self-employment

·         where minor equipment is provided, but nevertheless over and above what would generally be provided by an employee, this may be a pointer towards self-employment

·         Where the essence of the business is the exploitation of specialist skills and not the provision of specialist equipment, then the fact that the Client may provide the equipment is unlikely to be significant either way.

·         where the essence of the arrangement is NOT provision of skilled services and where equipment is required, the fact that such equipment is provided by the Client may be a pointer towards employment.

Comment

what would the position be likely to be in relation to this factor for a hypothetical employee?

·         logic and experience suggests that a hypothetical employee would probably utilise the Client's equipment, and provide either no equipment of any substance him / herself, save perhaps for (1) a car (probably claiming mileage other than to and from work);  (2) use of his own computer whilst working from home, if in fact (s)he ever did so.

what would the position be likely to be in relation to this factor for a hypothetical obviously self-employed person or consultancy (eg Andersens, or by PWC, or EDI?)  Logic and experience suggests that a hypothetical obviously self-employed person or consultancy would probably

·         also utilise the Client's equipment, where that is in effect the 'object' of the services, or where the nature of the business is primarily the provision of specialist skills, or when on the Client's site, to the extent that it is available and convenient to both parties to do so;  such use cannot reasonably be considered as anything other than neutral;  and

·         expect to provide his / her own equipment when on the Client's site where such equipment is not readily available and is needed as a tool to carry out the services, or in any event when working from his / her own premises, or where the Individual has incurred significant legitimate business expense in acquiring the equipment for precisely that purpose - which use can reasonably be considered a self=employment pointer.

do the facts here actually provide a helpful pointer towards either view?


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[1] http://www.inlandrevenue.gov.uk/ir35/guidance.htm

[2] http://www.inlandrevenue.gov.uk/manuals/esmmanual/part1000/esm1061.htm

[3] Ready Mixed Concrete (South East) Ltd v The Minister of Pensions and National Insurance (1968) 2QB497

[4] R W Proffitt Ltd v Secretary of State for Social Security

[5] WHPT Housing Ass Ltd v Secretary of State 1981 ICR 737