IR35 detailed comment


Taxation

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

The Revenue's guidelines are silent on the point, and probably regard this as reflected within the areas covered by 'Intention of the Parties'.

Independent businesses are required to manage their own tax affairs.

Employers deduct tax and NI by PAYE from salaries paid to employees, although employees may still have to make tax returns under self-assessment.

Comment

what would the position be likely to be in relation to this factor for a hypothetical employee?  Logic and experience suggests that in the case of a hypothetical employee, the contract itself would probably be silent on the point, it being taken as read that the employer make payments under PAYE as required by law.

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 in the case of a hypothetical obviously self-employed person or consultancy, the contract  would either contain an express term to the effect that the Individual would deal with his / her own tax affairs, or would be silent on the issue (but nevertheless expect such a term to be implicit).

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


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