HMRC Reporting Requirements For Agencies - 6th April - Lorien

[TheCyclingProgrammer]

They do apply, because the intermediary pays the ltd - and if you used a subcontractor, you'd have to report too.

Lots of debate around this in a previous thread on here which I won't repeat, but the above only applies *if* you're the top "agency" in the chain. In other words, if YourCo is supplied by Agency A to Client B and YourCo engages Sub-contractor C to work on the project, Agency A is also responsible for reporting on Sub-contractor C, not YourCo.

If however you are direct with Client B and "supply" Sub-contractor C you are treated as the "agency" and have to report, as things stand.

[RoastedSlopes]

I got one of these yesterday and just gave them the information straight away. What's the problem?

And a shiny green apple perchance?

[GlenW]

And a shiny green apple perchance?

No, but the young lady I deal with is particularly attractive, so I would be prepared to give her something else.

[FatLazyContractor]

Just received an email from the "Compliance department" that they would report me to the Account manager who will then discuss about me with the client.

I had a word with the Account manager and he agrees with me that I need not provide any info until they provide me the data security policy (which I presume, they don't have). Guess this AM is a relatively new guy

I replied to them with the Account Manager in CC and suggested that they should reply to my previous correspondence before they expect anymore information.

HTH

PS - Not advisable for everyone to do what I am doing. I handed in my notice last month and will finish my contract in second week of April, so I have nothing to lose (I believe!). Opted in and keeping evidence of everything I do by CCing my company email account in all client correspondence. Whether I am being foolish or not, let's wait and see

[TheFaQQer]

PS - Not advisable for everyone to do what I am doing. I handed in my notice last month and will finish my contract in second week of April, so I have nothing to lose (I believe!). Opted in and keeping evidence of everything I do by CCing my company email account in all client correspondence. Whether I am being foolish or not, let's wait and see

What will be interesting is what happens in this situation.

You have no contractual obligation to provide the information, but they have a statutory obligation to report it to HMRC.

Knowing who the agency is, I'd be tempted to wait until you get paid and then see if you can report them to HMRC for violating the regulations

[SpontaneousOrder]

Lots of debate around this in a previous thread on here which I won't repeat, but the above only applies *if* you're the top "agency" in the chain. In other words, if YourCo is supplied by Agency A to Client B and YourCo engages Sub-contractor C to work on the project, Agency A is also responsible for reporting on Sub-contractor C, not YourCo.

If however you are direct with Client B and "supply" Sub-contractor C you are treated as the "agency" and have to report, as things stand.

Thanks. This makes me wonder...

Does this:

One-person limited companies, or personal service companies (PSCs), that only supply a client with 1 worker don’t have to send reports to HMRC.

If the worker is supplied through an intermediary they will be included in the return of the intermediary that has the contract with the end client.

If a PSC supplies more than 1 worker, including any subcontracted workers, it will be acting as an intermediary and will have to send reports for each reporting period.

mean that if I supply a subcontractor instead of myself, while I work at a different client, then the agency will do the reporting? but if I supply a subcontractor to the same client that I'm also suplying myself (As a worker), then I will have to report to HMRC?

[Ticktock]

Thanks. This makes me wonder...

Does this:

mean that if I supply a subcontractor instead of myself, while I work at a different client, then the agency will do the reporting? but if I supply a subcontractor to the same client that I'm also suplying myself (As a worker), then I will have to report to HMRC?

The easy answer I spotted after my initial mistake is simply "whoever has the contract with the client is responsible for the filing".

So it depends if there is an agent in the middle, between the sub, you and the client.

[SpontaneousOrder]

The easy answer I spotted after my initial mistake is simply "whoever has the contract with the client is responsible for the filing".

So it depends if there is an agent in the middle, between the sub, you and the client.

But what about this bit?

(PSCs), that only supply a client with 1 worker don’t have to send reports to HMRC.

...

If a PSC supplies more than 1 worker, including any subcontracted workers, it will be acting as an intermediary and will have to send reports for each reporting period.

[Ticktock]

But what about this bit?

My understanding is that would be if you were going direct.

If it's YourCo -> Agency -> Client then the agency file the report.
If it's YourCo -> Client and only you actually providing the services then no report is needed.
If it's Subbie -> YourCo -> Agency -> Client then the agency file the report.
If it's Subbie -> YourCo -> Client then you need to file a report for the subbie.

[aoxomoxoa]

My understanding is that would be if you were going direct.

If it's YourCo -> Agency -> Client then the agency file the report.
If it's YourCo -> Client and only you actually providing the services then no report is needed.
If it's Subbie -> YourCo -> Agency -> Client then the agency file the report.
If it's Subbie -> YourCo -> Client then you need to file a report for the subbie.

What about if it's YourCo -> Consulting Firm (as an associate) -> Client ? Same as the first option above?