IR35 detailed comment


Services

The issue

The issue here is whether this the hypothetical contract here would be

·         a contract for services, or of service, or

·         some other type of contract

Legal issues, and the Revenue Guidelines

The Revenue guidelines appear silent on this issue, and do not appear to address the question of the dividing line between a contract of or for services, and 'some other type of contract'.

A contract for the provision of a specific deliverable may arguably not be either a contract of service, or a contract for services, but instead a contract for something else - a contract to produce a thing for a price. [1] Logic suggests this may apply even if the price is not fixed.

A contract to fill a post, or position, as opposed to for the provision of services (even if loosely defined) is likely to be a contract of service. [2]

It was made clear in Synaptek that this is the case, even where there is clear evidence that the individual was in business on his own account:

20. The fact that Synaptek (and notionally Mr Stutchbury) was in business on its (notionally his) own account is no doubt an important contextual circumstance to be taken into account in determining whether the particular notional contact under which Mr Stutchbury was engaged by the client was one for services or of service. But it is no more than that. The weight to be given to it was, in my judgment, a matter for the General Commissioners. That they took it into account is clear from their reference to the point in paragraphs 5.1 and 5.2 of the stated case.

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 be engaged for an indefinite period, in a specific and defined position, and against that background may be deployed on such services as here, possibly temporarily, as part of his general duties.  When these services were completed, or when the demands of the services were light, or when other demands were heavy, (s)he would generally expect to be redeployed elsewhere. 

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 be engaged to provide either specified and defined services for a fixed period, or to provide specified and defined deliverables.  When the fixed period ended, or when the deliverables were in fact delivered, the contract itself would generally come to an end.  If the contract was for services to be provided over any significant length or time, one might well expect it to be capable of being ended earlier by notice, especially if it were not for defined deliverables, to allow a degree of flexibility.  When the demands of the services were light, (s)he would not generally expect to be redeployed elsewhere.  When other demands were heavy, one would not generally expect him / her to be required to assist with such other demands.

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


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[1] Ready Mixed Concrete South East Limited v Minister of Pensions and National Insurance 1968 QB

[2] Fall v Hitchen 1973 1 WLR 286