back to article HMRC's IR35 tweaks have 90% of UK's IT contractors up in arms

Around 90 per cent of UK government IT contractors will rebel against proposals by HMRC to clamp down on self-employed workers not paying the correct employment taxes. The taxman is currently consulting on whether to shift responsibility for compliance with the intermediaries legislation, known as IR35, from the individual …

Anonymous Coward

Re: Why only IT?

Again referring to the HMRC consultancy document, they seem to consider most of IT within the scope of IR35 due to the use of business equipment, whereas a plumber (for example) uses their own.

This conveniently ignores the fact that in IT it is usually best practice, and in many cases 100% mandatory, to prevent the connection of devices that are not corporately managed to the network. This disctinction should IMO be written into the law as a justifiable exemption to the own equipment rule - you are using corporate equipment to comply with the security policies. That doesn't even factor in the possiblity of bespoke systems and applications that may be required to do the work, regardless of employment status.

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Re: Why only IT?

@Dr Syntax

"Indeed. In the printing industry they seem not to bat an eyelid about engaging sole-traders because that's how freelance graphic designers work."

There is a difference between a sole trader and a Ltd company. Sole traders generally get paid directly and then declare all earnings (minus some expenses) in a standard tax return.

Ltd contractors have another layer between them and the client.

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J P
Boffin

Re: Why only IT?

If you're worried about having to use engager's kit, Hall v Lorimer (1993 Ct App IIRC) is your friend - as the vision mixer on Have I Got News For You, he was able to successfully rebut* HMRC's argument that using the BBC's 8' wide mixing desk was an indicator that he was an employee. Apparently, in The World According To HMRC(TM) any self respecting self-employed vision mixer owned their own £250k mixing desk and hawked it around the country, from show to show. Thankfully, the Court of Appeal had a slightly closer grasp on reality than HMIT Hall, and we now have a persuasive precedent that actually accords with the world as experienced by normal people. [for anyone who wants to know just _how_ close a grip the senior judiciary keep on reality, the excellent Steve bell cartoon at http://www.belltoons.co.uk/bellworks/index.php/if/1985/1082-0-0-85JUDGESPAYCLAIM should help. nb it's 30 years old now, so the inflation rates are a bit crock)

*I think I've got the right word there, but if it should be refute I apologise. It's late... *checks watch* ... early and I've had a long day. And a glass or two of wine. Sorry; it's the weekend.

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Re: Why only IT?

only tax stupid people? Yes, there are a lot of them and they don't fight back.

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J P
FAIL

It's not just about indvidual contractors

By shifting the burden of IR35 compliance up the chain, they'll create an environment where the non-application of the anti-avoidance rule has to be documented up front by either the agency or the public sector body. And that'll have to be done for every contract where there might be disguised employment in HMRC's eyes - not just the hiring of specific individuals for specific roles, but also the more generic stuff like typing, gardening, plumbing etc. where it could be done by an employee (but isn't).

And contrary to popular belief (and HMRC's proposals) it doesn't have to be via a company; the law allows for an IR35 charge to hit partnerships or even individuals who subcontract their work. ( http://www.legislation.gov.uk/ukpga/2003/1/part/2/chapter/8 specifically s51, 52, 53. nb changes to s49 re office holders via "view outstanding changes"). And this rule will apply to every GP surgery, every parish council, every police force and every other public body in the country. That's 9,637 parish councils who need to document the IR35 position for their website manager, maintenance contracts, typists and (joy of joys) auditor. (Auditor's a funny one; they're "officers" so de facto caught by IR35 *unless* they can demonstrate there's no "intermediary" within the statutory definition).

The argument about social contribution vs tax paid vs benefits supplied by the state is a valid one, but this is a particularly wasteful way to go about policing it, without in any way addressing the underlying issues.

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Re: It's not just about indvidual contractors

"And that'll have to be done for every contract where there might be disguised employment in HMRC's eyes - not just the hiring of specific individuals for specific roles, but also the more generic stuff like typing, gardening, plumbing etc. where it could be done by an employee (but isn't)."

That should improve things no end. If there's a clear distinction between contracts for services and contracts of service we'll probably see appropriate contracts offered for a change and none of this non-matching clauses between the client/agent and agent/freelancer contracts nonsense.

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Re: It's not just about indvidual contractors

Unfortunately the average contractor cant afford the international tax lawyers required to setup a chain of parent shell companies in off shore locations and pay tax experts to use dodgy mechanisms like "loyalty fees" to extricate money tax-free to those off-shore tax havens. like Amazon Starbucks Google IBM et al do.

They are lucky if they can by into a second-hard car reselling business that runs with negative profits.

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Interesting...

I find the squawking around IR35 interesting, especially some of the above comments... I would sincerely hope that those protesting they are paying their tax are not the same on here who then turn around lambasting Amazon et al for employing aggressive tax accountants to minimise their tax exposure? After all, they just do what you do, just on an appropriately larger scale. They do after all pay *their* taxes too.

Back when I was in the contracting game (yes, I was, during and after IR35 introduction), there were several organisations catering exclusively to contractors who prided themselves in 'cost recovering up to 95% of your earnings' by using the system in such a way that you effectively dodged paying employer and employee NI and taxes as much as possible (after all, that's the disadvantage of having a Ltd - you get to pay both!). By paying yourself the minimum wage (and paying employer/ee NI and PAYE on that) and taking the rest as a dividend every month (which *is* legal, after all, and possibly having to paying the vastly reduced tax on that), your tax exposure was, well... minimal. Add to that the cost recovery of travel expenses, the per diem, accommodation expenses etc, you truly could recover something like 95% of your high daily fee.

Was it sailing a little close to the wind? Perhaps! But then again, that's why Amazon et al are getting their arses roasted... that too many people find that morally reprehensible.

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Re: Interesting...

That's fair enough. Similar to if you don't vote, you can't complain about what the Govt. / Local Council etc. do.

As a contractor myself, who does end up with periods between work, and pays myself a salary (my Ltd. takes the daily, I as an employee see a fraction of that), I have no qualms about paying NI and Income Tax and also any tax due on Dividends, as well as my Ltd. paying its Corp. Tax.

However, if HMRC wish to change the rules, and further increase taxation upon contractors and their Ltd. companies, then they best be damned sure they chase the Hyper-Global-Mega-Corps to pay their share also, and not let them get away with paltry amounts due to such companies being able to "Lawyer Up".

It just comes across as HMRC going after the easy pickings of going after the little guy because the paymasters do not wish to upset "Big Business".

I believe the term is flat-track bully.

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Re: Interesting...

If you are running through a Ltd company in a standard way, you are paying a fair amount of tax - the combination of corporation tax, income tax on dividends certainly adds up to a significant percentage of my income, not ever so far from the proportion I was paying when I was permanent and that is ignoring VAT which is its own thing. I prefer to work this way but it has nothing to do with paying less tax and the same is true of most of the contractors I work alongside.

I think where people really do it for tax avoidance they may be more at the level of chief executives working through consultancy companies and the like. That seems quite common - particularly in the public sector - and it does seem as though there might be reason to mitigate it as possible.

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Re: Interesting...

Can't speak for others here, but I'd like to see some policing of 3rd party companies who are advertising such services as 95% take home.

As a LTD Company contractor, my details are on file at Companies House, and spammers/scammers call me on an almost weekly basis offering services that sound too good to be true. Therefore, IMO, are. I don't pay myself a small salary for the avoidance of tax, I do it so that I can keep a steady and guaranteed income even when I am not working, and top that up with dividends when finances allow.

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Re: Interesting...

I couldn't agree more with the point on small salary, Franco. Someone else mentioned in a post further down about contractors buying 911's etc. and those individuals doing so being idiots. I've known the odd one or two who splurged all their company revenue as income and then shat it when the tax bill arrived.

I've been honouring a private contract / project that, due to *my* own terrible initial time estimate, has meant I have not billed my client for the past 4 months. There is probably another month left before all parties can say “mission accomplished”.

Yes, my friends say I am insane. Yes, I was extremely naive in my re-negotiation when it became glaringly obvious that the initial time estimate was way off the mark. Yes, in terms of cold hard revenue to my company, it has taken one hell of a hit as a result.

However, as you and so many others have pointed out here, there's reserves in the Ltd. company for such times (mainly between contracts rather than non-billable work, granted). Call me old fashioned, but I felt guilty when I realised the magnitude of what was needed to deliver the project, and I felt acutely aware that people would only see the headline figure of the daily and think I was trying to take the piss out of the client.

So, to try and act with a little integrity (or just plain stupidity), rather than just shrug my shoulders and say “them's the breaks Guv', I'll still need you to cough up £X per day until I'm done, and that could be three, four, five months down the line. Who knows!?”, I chose to honour the initial delivery, no extra cost to the client beyond my initial time estimate.

The flip side is, the client is so appreciative (of course they are very happy to date) of me being honest and not being seen to just fleece them, is they wish to get this phase wrapped up pronto also, so we can move forward and into future phases, whereby things will be planned much, *much* more meticulously so (I) don't end up in the same situation of working pro bono for so long, ever again. I've just viewed it as a learning experience, and a bit of volunteer work on my part.

Being a prudent contractor over the years has enabled me to survive.

TLDR: I bodged a time estimate, felt guilty, so am honouring the initial project spec at no extra cost to the client.

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Anonymous Coward

Re: Interesting...

I feel your pain.

I had a client who insisted on fixed price quotations for everything. Which was fine for tasks that could be reasonably estimated and relied on no other inputs. Sleepless nights though when trying to include third party integration and longer time scales. After some negotiation a PO would be raised and I'd do the work, get it signed off and submit an invoice. Payment terms I negotiated down to 45 days from their "standard" 90 days - piss takers. All was fine when I underestimated the work and they got my time for free. But when it was the other way around they complained I was ripping them off - remember they had already agreed the scope, time scale and issued a PO!

In the end I gave up and found an hourly paid contract. God help the next mug they try and use as slave labour.

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Re: Interesting...

I would sincerely hope that those protesting they are paying their tax are not the same on here who then turn around lambasting Amazon et al for employing aggressive tax accountants to minimise their tax exposure?

Actually I think you'll find there's a negative correlation between these two.

The ones paying the proper tax will also (in general) be the same people who understand that however much we may feel it is in some way "unfair" - what those companies are doing is working within the rules laid down by the various governments.

If people don't like what these companies are doing, then the aggression should be aimed at those responsible for the rules which allow it.

And for the record, I employ a tax avoidance scheme - in fact I have several. And it's all legal, and even promoted by the UK government and HMRC. In fact, most people use tax avoidance schemes - it's now even a legal requirement for employers to provide a scheme and sign people up to it unless they opt out.

And what is a tax avoidance scheme ? It's simply an arrangement, within the rules as laid down by the authorities concerned designed to minimise as far as is permitted by those rules the amount HMRC may shovel from your pocket.

.

This is the think that the Daily Wail and Stun readers just don't understand. It is not illegal to arrange your affairs within the rules laid down so as to minimise how much tax you pay.

.

.

For the hard of thinking, the avoidance schemes I refer to are things like pensions, ISAs, and so on.

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Anonymous Coward

The State: A masterclass in going after easy targets, while leaving big players alone...

Isn't it amazing how efficient and overreaching the State is when they want to screw the little guy... Yet they always overlook the big tech boys... I wonder why :p ... Fuck slaving for the State anymore, I'm off to Hong Kong / Dubai. Paying taxes for what? How many will even live long enough to earn a pension back ??? :

http://www.thisismoney.co.uk/money/pensions/article-1679780/New-state-pension-age-retire.html

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James Avon Clyde (Lord Clyde) said it best

""No man in the country is under the smallest obligation, moral or other, so to arrange his legal relations to his business or property as to enable the Inland Revenue to put the largest possible shovel in his stores. The Inland Revenue is not slow, and quite rightly, to take every advantage which is open to it under the Taxing Statutes for the purposes of depleting the taxpayer's pocket. And the taxpayer is in like manner entitled to be astute to prevent, so far as he honestly can, the depletion of his means by the Inland Revenue"

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Pint

Re: James Avon Clyde (Lord Clyde) said it best

Tony- have an Internet!

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Re: James Avon Clyde (Lord Clyde) said it best

And that ruling is law (case law). And I seem to recall there is also another piece of case law that says broadly say the same thing.

P.

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J P

Re: James Avon Clyde (Lord Clyde) said it best

There are three bits of case law which say the same thing. They're quoted here https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/396179/gaar-part-abc.pdf in the guidance on the implementation of the General Anti-Abuse Rule which Graeme Aaronson QC developed for the government, specifically to displace that case law precedent. He's gone so far as to openly declare that in public lectures. Subsequent statute trumps case law I'm afraid, even House of Lords.

If you attempt to rely on "the Westminster principle" in front of a UK tax tribunal these days they'll ignore it. (There are some jurisdictions which still operate on that basis, but it's a diminishing proportion. Civil Law codes have never really gone for it at all, generally incorporating some abus de droit principle. Which is why UK VAT avoidance disputes, relying on the European civil code background of VAT, always played to a different set of rules to direct tax avoidance)

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Re: James Avon Clyde (Lord Clyde) said it best

"Tony- have an Internet!"

Just make sure that its clear that it is given as a tax free prize, you dont want to end up liable for CGT on the the whole internet!

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So you an Employee not a contract

In that case you can write to all your past contracts and demand holiday pay, pension and other rights that you never got.

It will only be a matter of time that some take UK gov to court demanding this for a UK gov project.

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Anonymous Coward

Re: So you an Employee not a contract

>In that case you can write to all your past contracts and demand holiday pay, pension and other rights that you never got.

You'll need a legal ruling first - HMRCs opinion only effects you - the employer will be also liable to fines etc not just your missing pension and chances are they'll have better lawyers than the HMRC. Ultimately you'll lose.

Better to pool resources with other contractors, create an agency, hire in some tax expertise and pay whatever tax you think is reasonable.

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Its broke

The whole tax system is broken and needs to be reset for the modern world. We have some people being taxed into the ground to the point its almost not worth them getting a pay rise because it makes no difference to their bottom line. They just get more stress with little extra wage to compensate. They are stuck in a tax band with nowhere to go.. Then there are people and big companies that can avoid paying any tax at all. After all this the government still doesn't have enough money to pay for the services we need. System is broken.

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Anonymous Coward

Joined up government

Here's an idea - if the government doesn't want people working through personal service companies, it doesn't have to introduce new legislation or change tax law, it can just refuse to use that style of contract.

Oh, it wants the benefits of flexibility in staffing without the disadvantages? Cake double-counting ahoy.

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Anonymous Coward

Re: Joined up government

Oh, it wants the benefits of flexibility in staffing without the disadvantages?

And HRMC know all about cake and eating it; basically, you've summed up in a few words what the Aspire contract was really about.

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Anonymous Coward

Re: Joined up government

"And HRMC know all about cake and eating it; "

Are they still living in Mapeley Steps tax avoiding offices?

Damn, they need to evict the tenants from offices owned out of tax shelters, right now.

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Re: Joined up government

@Anon

"if the government doesn't want people working through personal service companies"

I'd like to set you a challenge.... Find a definition for "personal service company" on any HMRC or government source. Part of the problem is that they cannot nail down what they consider a PSC to be.. but at the same time they want to tax PSCs differently.

I assume that you are on payroll somewhere with an 110L Tax code... How would you feel if HMRC suddenly decided that everyone who they class as a "Secure Permanent Employee" would be moved to the BR tax code? Does it affect you? Are you what they class as a Secure Permanent Employee?

Take a few seconds to think about how you would feel if someone turned round to you and said that based on some arbitrary rules that are not actually defined anywhere (So you cannot hope to follow them) that they were going to increase your tax by 20+% how would you feel about that?

While you do the above bear in mind the additional tax and overheads that contractors incur that you dont have to pay, and the benefits that you get from your employer that we dont get...

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" to clamp down on self-employed workers not paying the correct employment taxes."

Shouldn't that be:

"to make self-employed workers pay the same taxes as if they were employees" ?

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'Shouldn't that be:

"to make self-employed workers pay the same taxes as if they were employees" ?'

No. It should be "to treat small outsourcing businesses as employees whilst Capita etc still get treated as businesses".

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Everything will balance out just fine.

Contractors will raise their rates to offset the higher taxes; but the public sector will be able to afford those higher rates, because the tax take will be higher. It's just more money cycling through HMRC's hands.

(Yeah, I know that's not really gonig to happen in practice.)

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Anonymous Coward

Final note first:

I think the general individual doesn't want a contractor to increase their day rate - the truth is I suspect people don't like the fact that intelligent professional consultants with expertise charge a lot of money and can out-do them technically, which is the reason we are sourced in the first place to help expedite projects!

_____________

Contracting through a Limited Company structure is NOT 'self-employed'. Self-employed is an unlimited liability company and is entirely different from a taxation point of view.

Less than 1% of contractors using a Limited Company structure did the following in the past:

*Earn a day rate from client(s)

*Maximise expenses for staying away from home

*Pay themselves a small wage for NI purposes

*Send money offshore and receive 95% back as a loan from a dodgy company

All the above are legitimate except the last one! There is now a dividend tax to ensure contractors pay more tax - if you hold dividend-paying shares then you will also be paying this dividend tax if it is above £5000 per tax year.

Your average Joe Contractor is not dodgy and will have the Limited Company they are a director of paying their own pension, health insurance, holidays and everything else a permanent employee accepts as part of a remuneration package.

99% of contractors are not dodgy and are simply providing services through the only viable existing method which accounts for the ability to have the same benefits as a permanent employee but - importantly - *PAID FOR BY THEMSELVES* (in the form of money brought into said Limited Company).

If you can't understand and are annoyed that someone has bought a brand new Porsche911 as a contractor then remember this: some contractors are idiots with no future plan, no savings and no understanding of the tax system. Much like your average permanent human in the UK, they spend beyond their means.

If someone chooses to spend all their cash now then you can safely be assured - regardless of employment status or style - their risk of trouble in the future is heightened. Don't for one second think contracting is a 'get rich scheme' with people avoiding tax. I can assure you it absolutely is not.

Thing thing to target to get more revenue for HMRC is offshore shifting of monies - it's still happening on a massive scale and accounts for billions missing in the exchequer. In a sense it is not entirely legal.

I'm an experienced consultant and my average income post-tax for the past decade is the equivalent of £65,000. I can earn more in a permanent job but enjoy running my own business, working on programmes requiring a lot of expertise and new technology and managing my own personal development. If I work away from home I do claim most things - but as a permanent employee working from home you also have your accommodation and what-not paid for, so what's the complaint?

To punish those who function through these structures and are not using offshore schemes seems an easy way to increase costs to clients; either by said clients using large professional services (Deloitte, PWC, Accenture, etc) or an increase in day-rates from £500/day to £700/day to compensate.

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Corrections:

Thing thing = 'this thing'.

£65k salary = PRE-tax permanent salary

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@Shark Tank

Did you forget to post as an AC?

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Paris Hilton

@ Shart tank

Ha Ha!

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"intelligent professional consultants with expertise charge a lot of money and can out-do them technically, which is the reason we are sourced in the first place to help expedite projects!"

At the top end, maybe. Another factor is the manager who finds that he needs somebody RIGHT NOW. Possibly because he's just get a new urgent requirement dumped on him, a deadline brought forward, someone has left/fallen ill/gone on holiday or maybe just downright bad planning. Even if it's not a hugely immediate requirement there may still be a need to match fluctuating workload with a static allowed permanent head-count.

That floating population of workers allows the permies to have their more or less secure jobs, benefits, pension schemes etc because the alternative would be to make all jobs casual. The means by which the contract market can fill jobs on an ad hoc basis is by having a proportion of the on the bench at any one time. It's part of the T&Cs that the market offers, it costs money to provide which thus goes into the charging structure and is the reason why freelancers should be treated as bona fide businesses.

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Anonymous Coward

More IT contractors available in the UK after Brexit?

As professional services are one of the UK's largest exports and we can expect large tariffs on them post-Brexit, I imagine the pool of local contractors will increase, driving rates down, by the time this IR35 iteration is implemented.

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Anonymous Coward

Re: More IT contractors available in the UK after Brexit?

Luckily, some of us now have dual passports and will still be able to go elsewhere and contract. Some of us even have the language skills to take on the vast pool of non-English speaking contracts.

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"employees without the benefits"

Let's clear up one thing.

Contractors are paid a gross sum from which the Limited Company is expected to provide ALL the benefits for the "employee" - salary, holiday pay, sick pay, pension, health care, critical illness, jury cover, car, gym membership, etc, etc, etc. If you as Director choose to only provide a small salary as a benefit that's your choice, but you have been paid by the engaging company to provide all the benefits, that's why it's usually at a higher rate.

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Anonymous Coward

You can work inside IR35 and pay perfectly ok taxes

But every stupid contractor I talk to won't take the time or trouble to figure this out.

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Anonymous Coward

Re: You can work inside IR35 and pay perfectly ok taxes

But why would you, unless you were doing the same job an employee does? You should be consulting/contracting primarily to do the roles a permanent employee *can't* compete with - Helpdesk shifts and such-like is a good example of (in my opinion) being well inside IR35.

Looking XYZ expertise and then tendering out to agencies/consulting firms essentially means it's a b2b endeavour.

I don't want employee-permanent style pigeon-holed job, which is why IR35 doesn't apply to moi - I have no interest in taking such limited roles. Each to their own! I'm not fraudulent, I really do take outside IR35 rules, but all Public Sector roles are soon to be considered within IR35. I can assure you the actuality is that they are NOT all inside IR35 as the Public Sector need consultants as much as the private sector.

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Re: You can work inside IR35 and pay perfectly ok taxes

"But every stupid contractor I talk to won't take the time or trouble to figure this out."

What's probably happening is that the contractors who understand it perfectly well, know you're wrong but can't be bothered to argue with stupid.

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Anonymous Coward

Re: You can work inside IR35 and pay perfectly ok taxes

If you are taking on a role then it is usually just another job. If you are contracted to deliver an agreed outcome then it is not.

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Doesn't really reflect what the market wants..

To me this goes against what seems to be the future of employment. Who can even think that 'permanent employment' still exists? Whats the usual turnover for the typical employee? 4 Years?

Personally I'm all done for the corporaty lure of a 'culture' and associated bullshit. I've seem so many times every time I now see an executive haranguing his 'family' I want to vomit.

What I want is to be able to do as I want, I particularly enjoy playing the mercenary as a contractor, I embrace the fact I can hop on a project, have an impact, and then leave. That doesn't mean that some projects can't be longer than a couple of years, the spirit stays the same, I'll still go when it finishes.

The cruel bit is, as an employee, I was the exact same over-competent guy, and more often than not my opinion was completely ignored as I was drowned in the corporate politics. Now as a contractor, I'm paid so much people actually pay attention! People try not to waste my time with idiocy, people think twice about inviting me to meetings, and take notes when I make recommendation.

I don't want to have to be rolled back into a corporation. I'm happy to pay my taxes, but my taxes must reflect that I don't get any of the perps permies do. On the other hand, yes, I'd like to be able to have a way to differentiate myself from the typical contractor-typist who's been at the same desk for 10 years; the worst bit is, it's his agency who's making the money!

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Anonymous Coward

Re: Doesn't really reflect what the market wants..

Explain to me why you don't get the perks of a permie? You presumably earned a higher rate than the permies but spent it all rather than keeping some back in your limited company so you could pay yourself holiday pay, sick pay and contribute to a (tax deductible) pension plan. Plus you got perks such as travel expenses that a permie never got. Sounds like whoever actually employs you and pays your salary, NI and PAYE is taking you for a ride. But that would be yourself though wouldn't it?

What you bill your customer isn't "income" it's "revenue" into your limited company and any contractor who doesn't get this fundamental difference deserves to be shafted by IR35.

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Re: Doesn't really reflect what the market wants..

"people think twice about inviting me to meetings"

I like to "jokingly" tell people that their meeting just cost the company £x00 as I leave.

There was one *quick* half hour meeting which was held by a permie PM and a small team of contract developers (some of whom were quite specialist) we worked out the company was paying approx £10-15 a minute for us to be in there.

The whole meeting should have been an email with a project plan attached.

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Allow permie IT staff some of the perks?

maybe even it up a bit and allow permie IT staff some of the perks like being able to offset stuff against taxes like travel, cars, equipment, training, lunch. No, thought not. There are lots of permies who for one reason or another only last a year or 2, the same as some contractors. Maybe the answer is to tax contractors like permies and pay the rest back to them once they've moved on to a different company. That way everyone wins, or doesn't.

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Re: Allow permie IT staff some of the perks?

> maybe even it up a bit and allow permie IT staff some of the perks like being able to offset stuff against taxes like travel, cars, equipment, training, lunch. No, thought not.

You mean the free training, travel costs to go off-site, pension, sick pay, redundancy pay, maternity leave, subsidised canteen etc. your company provides aren't enough?

If you'd rather pay for those and offset them so you end up paying 80% of their cost, that's absolutely fine by me. Just be sure to do the training in your own time.

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Re: Allow permie IT staff some of the perks?

"maybe even it up a bit and allow permie IT staff some of the perks like being able to offset stuff against taxes like travel, cars, equipment, training, lunch."

How about an alternative? Tax everyone the same on income but treat permanent jobs as a benefit in kind to be taxed appropriately. The extra tax from the b-i-k part can be used to reduce existing PAYE/NI rates. That's fair, isn't it?

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