- Examining the off-payroll IR35 rules’ draft PAYE debt transfer provisions
- What is the purpose of this draft secondary legislation?
- How does it sit alongside the draft legislation published in July 2019?
- How will HMRC recover unpaid PAYE liabilities from April 2020? What is the proposed chain of recovery?
- What can engagers do, if anything, to minimise the risk of HMRC seeking to enforce this secondary liability against them?
- Does this draft secondary legislation envisage any changes to Real Time Information returns?
- Do the NICs provisions mirror the income tax provisions?
- How does the publication of this secondary legislation affect the current government review of the off-payroll IR35 changes?
- What are the next legislative steps?
- What should engagers of contractors be doing in advance of 6 April 2020?
Tax analysis: Constantine Christofi, associate solicitor at RPC analyses the recently published draft secondary legislation, which forms part of the package of measures that will implement changes to the off-payroll IR35 rules from 6 April 2020, and considers what actions engagers of contractors should take before the new rules are in place.
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