IR35 - The 'Contractor Tax' Demystified

Contractors and freelancers who choose not tothe contractor did not have an intermediary like
be permanent employees and work flexibly fortheir limited company between them and the
many clients have been targeted by UK taxclient, they would be a permanent employee and
legislation called IR35. IR35 tax legislation isshould be taxed as such. This is why IR35 is also
designed to tax as if they were 'disguisedcalled the 'Intermediary's Legislation'.
employees' workers providing their skilled andHMRC uses key 'tests of employment' to check if
predominantly knowledge-based services to clientsa contractor is a disguised employee, including:
via their own limited company. IR35 can result in- Whether the contractor is controlled, or told
these workers losing up to 25% of their normalhow to work, by their end user client
take-home pay in extra taxation.- The ability of the contractor to use a substitute
Unfortunately, IR35 was poorly thought throughon the contract - Mutuality of obligation, or 'MOO'
and subsequent tax tribunals and court cases- where an employer is obliged to provide work
have made things so complex that prudentand an employee is obliged to do it.
contractors pay professional advisers to ensureGenerally, if a contractor fails one of these tests,
they are not caught by IR35.a tribunal or court will find that they are outside
Her Majesty's Revenue and Customs (HMRC)of IR35 and so do not have to pay extra tax as
mounts IR35 investigations into many contractors'an employee. Unfortunately, though, tests of
tax affairs every year, and is able to investigateemployment are rarely straightforward. So
contractors' tax returns and working practices upcontractors can undergo long periods of stress
to six years in arrears. And many contractors endduring the course of an IR35 investigation, and still
up in IR35 tax tribunals or court cases becausefall foul of IR35 legislation due to technicalities.
they dispute having to pay the extra taxThere are easy actions contractors should employ
demanded.to reduce the chances of them being found within
When deciding on whether or not a contractor isIR35, eg to invest in tax investigation insurance,
inside IR35 and therefore must pay extra tax,to get contracts checked by an expert, and to
HMRC inspectors - and later tax tribunals andget clients to confirm the contractor's working
courts - look at three key areas:arrangements.
- The written contract between the contractorContractor organisations have tried to abolish IR35
and the agency and end-user clientfor many years, but it is likely that the legislation,
- The contractor's business as a wholeor something very similar to IR35, will remain on
- The actual working relationship between thethe statue books for the foreseeable future.
contractor and their client.Therefore, contractors should always ensure they
What tax inspectors want to prove is that themanage their contracting careers so that they
contractor is really a 'disguised employee', and ifnever fall foul of IR35.