IR35 detailed comment


Opportunity to profit from sound management

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

Opportunity to profit from sound management - A person whose profit or loss depends on his capacity to reduce overheads and organise his work effectively may well be self-employed (Market Investigations Ltd v The Minister of Social Security). People who are paid by the job will often be in this position.[1]

The following paragraphs are extracted from the Employment Status Manual, section ESM1035:  [2]

The Courts have concluded that a self-employed person often has an opportunity to profit from the sound management of the task. Of course an employee's income may also be related to his or her efforts or to other factors and so may not be regular or constant.

An employee's income will depend on performance when paid by the piece. It could also depend on how long he or she works and that, in turn, could depend on outside factors such as the weather.

It follows that the Courts interpret the opportunity to profit from sound management in a rather special way. What they have in mind is the worker who quotes a fixed price for a job and whose profit or loss depends on speed and efficiency and the capacity to reduce overheads and organise work effectively.

A few words of comment are called for on the last sentence:  it appears purely speculative, and is (to the best of my knowledge) entirely unsupported by any legal authority.  I will go further than that:  it represents an argument the Revenue presented in the Hall v Lorimer case.  They presented it as follows:

(the Revenue barrister said) '…the production company in any given engagement controlled the time, place and duration of each programme, that Mr. Lorimer did not provide any of his own equipment, that he hired no staff to assist him in his work, that he ran no financial risk apart from the risk of bad financial debts and of being unable to find work, that he had no responsibility for investment in or management of the work of programme making and consequently he had no opportunity of profiting from the manner in which he carried out individual assignments.'

And by way of answer to that argument, the Court approved the following comment from the Special Commissioner who first heard the case:

"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."

So, despite the Revenue's statement:

It follows that the Courts interpret the opportunity to profit from sound management in a rather special way. What they have in mind is the worker who quotes a fixed price for a job and whose profit or loss depends on speed and efficiency and the capacity to reduce overheads and organise work effectively.

it would appear that in fact what the Courts have in mind may be - and in that case was - the opportunity to profit from being good at what you do, and thus hiring your services out from time to time to the highest bidder.

A slightly more subtle point is that it appears the Revenue were seeking to suggest that 'opportunity to profit from sound management' simply meant 'in relation to the particular engagement'.  However, the view expressed by the Court in Hall v Lorimer and approved there by the Court of Appeal can only be interpreted to mean 'in relation to the business as a whole'.

The position of the Contractor:

·         The conventional picture of the self-employed tends to be of starting from scratch, and then gradually build up a business, and having the opportunity to profit from sound management by acquiring new sources of income, doing work efficiently or in less time, and containing overheads.

·         The Contractor is in a slightly unusual position.  Instead of starting from scratch in the same way, (s)he will generally make a move from employment straight into contracting, thereby immediately securing a substantial increase in gross income. 

·         (S)he has taken the decision to migrate from the security of employment, to surrender the benefits and security of employment, and to make the move to contracting as a career, and to accept and manage the resultant risks him / herself.  Indeed, it may be reasonably be argued that by doing this alone (s)he has already taken advantage of a significant opportunity to profit from sound management. 

·         Wise choice of engagements, and wise anticipation of future skill requirements, coupled with training as necessary to be able to meet such requirements, may also be examples of ways in which there is opportunity to profit from sound management.

Profit however is not simply income, but the balance between income and expenses.  Expenses still need to be contained, and profits will be eroded if expenses are not managed soundly - ranging through

·         expenses over which there is a degree of direct control (eg telephones, stationery, insurance, wise exercise of rights to substitute, paying for administrative assistance in order to preserve potential fee-earning time etc)

·         expense more in the nature of investment, such as skill maintenance, training, and development (whether paid for, or in what would otherwise be fee-earning time) - especially training where there is no certainty that the investment will be recovered;  equipment;  reference materials

·         taking steps to preserve profit by guarding against the risk of loss

Where there is the opportunity to manage these and other such items and thereby affect profit, there is opportunity to profit from doing so soundly - to profit from sound management.

Note that it is the opportunity to profit from sound management that counts - whether one does in fact 'soundly manage' may be quite another question, and certainly not relevant here.

Perhaps oddly, it is also at least arguable that the opportunity to structure one's affairs by negotiating IR35-friendly terms where it is proper to do so could properly regarded as opportunity to profit from sound management, since (1) doing so would appear to be management, and (2) it offers opportunity to profit from doing so;  such a proposition may be supported by Hall v Lorimer [3], where the incurring of expenses which would be tax-deductible by the self-employed was held to be itself a pointer towards self-employment

Case law appears to suggest:

·         if a worker has significant opportunity to profit from sound management of the business as a whole, then the relationship is likely to be self-employment

·         'opportunity to profit from sound management' may mean (1) from management of the task itself, or (2) from managing the business as a whole - the opportunity to profit from being good at what you do - and from building a reputation and a demand for your services, for which you can charge accordingly

·         if a worker can increase his net earnings he may be self-employed, but other factors need to also be considered;  this may be a pointer towards self-employment, but not necessarily conclusive in itself

·         it may be unlikely for the relationship to be self-employment if there is no opportunity to profit from sound management

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 receive a salary and benefits package;  and that such salary package might well be reviewed from time to time, taking into account performance.  Additionally, the employee might receive occasional bonuses.  Beyond that, the employee has no apparent opportunity to profit from sound management, and simply receives a set salary, regardless of effort, illness, or other vagaries .

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 plan the growth and development of the business, so as to continue to be able to take advantage of the best opportunities available;  investment in skill development and equipment;  and manage and control expenditure.  By having the opportunity to do such things, there is the opportunity  to profit from sound management, which the employee does not have.

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/esm1035.htm

[3] Hall v Lorimer 1994 IRLR 171