Direct and outside, to potentially inside

[PSChick]

And the agency reporting requirement is designed for things such like this. Ones where you look at say February 2020's record and compare it to May 2020's and search for National insurance codes in both reports but where the third party payer has changed. You then check the tax paid in the two months and if significantly different add to the list "of give them a scare and quick shakedown" letters.

When these changes were implemented in the public sector 3 years ago S3 group explicitly moved any contractor going from outside IR35 to inside IR35 to a different agency to avoid people showing up on such reports.

Aha yes that makes sense. I am in the fortunate position of having only had a year via an agency during the last 5. The rest have been direct deals with the client. I would therefore have last appeared on an agency report over 3 years ago, and since then my NI number would only be on salary paid by the PSC and of course my tax return.

On that basis, that is probably one "red flag" that won't apply to me, whatever happens.

[dsc]

Bear in mind that, post April, large clients are more likely to be targeted for all of their juicy targets, rather than individual contractors. You already see this direction of travel from GSK etc. But, yes, the agency reporting requirement is another useful tool to help them join dots, only applicable in that context.

Even if the client doesn't share it's list of 3rd party suppliers with anyone, it would be fairly easy for HMRC to simply come over, do a quick inspection based on the fact that some outside assessments were done pre April and then start a detailed look into everyone who's apparently outside. I'd venture a guess and say that the smaller the client the lower the possibility of this happening though.