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[jamesbrown]

No, the client is answering truthfully. They disagree that a valid substitution occurred. The OP provided no specific examples, according to the client, and the client has no record of any substitutions. Again, CEST is a sideshow here and the thoughtful response from the client makes that very clea...

[jamesbrown]

So...?

Does anyone think that CEST reflects case law on any major aspect (RoS, MoO, D&C)?

The bigger picture for the OP is that the client is clued-up and thinks the OP is inside. That the client read the CEST guidance and doesn't believe that the previous "substitutions"...

[jamesbrown]

Er, they aren’t niche for people that do them. There is no “market” - it’s a stupid abstraction....

[jamesbrown]

Many sectors pays that much for the right talent in the right specialism. Obviously, you’re not going to get that as an average IT person, but those numbers are pretty routine for actuaries, interims and some medical and engineering roles....

[jamesbrown]

A minor point of detail though - the test is not an "unfettered right", rather a "not unreasonably fettered" right.

[jamesbrown]

This is an unusually clued-up client, so I'm afraid you're a bit stuffed.

Agree with the sentiment that this client must have some high-value contractors to protect, otherwise they'd have been stupid to bother with PSCs; and they seem the opposite of stupid.

[jamesbrown]

I'm even up 20% on my stupid Lloyds punt.

You really have to be a weapons grade scootie to have lost money recently.

[jamesbrown]

He's got a thing about robots calling him "big boned"....

[jamesbrown]

They’re already in MF’s bedroom....

[jamesbrown]

Surely you meant, MPs and their Financial Innerests?...

[jamesbrown]

Yes (but that's a lot of stuff and there are vested interests in not doing it). ...

[jamesbrown]

The problem arises because the ITEPA and related legislation puts an agency or end-client on the hook if a self-employed person fails to pay the appropriate taxes. You may find a willing client with whom you can work directly. But the main reason to not work in this way is unlimited personal liabil...

[jamesbrown]

Let 'em have it.

[jamesbrown]

Well, in that case, have three bananas.

[jamesbrown]

Let's be clear that the risk began the moment you started working for this client. Most likely, they've always viewed the role as being inside. It's always best to get the client's view in writing if possible (e.g., a confirmation of arrangements). Of course, the other possibility is that the client...

[jamesbrown]

In other news, the world's biggest packet of puff pastry was stolen from the Worcester branch of Aldi early on Sunday morning.

[jamesbrown]

Unless you're earning 20k or being massively ripped off, it isn't going to be 6%.

Practically speaking, the liability falls on the supply chain if IR35 isn't operated properly and, while it's theoretically possible that the Fee Payer could operate payroll and pay the deemed payment to YourCo,...

[jamesbrown]

The only circumstances in which it wouldn't be subject to CGT would be trading income, in which case it may be subject to income tax.

Incidentally, the gain is most likely realized upon any transfer, not just from a crypto token to fiat, but from one type of crypto token to another....

[jamesbrown]

I don't think IR35 (or the Off-Payroll Working Rules, aka Chapter 10) has any bearing on this, since it's tax legislation (ITEPA), not about employment rights (in case that's what you were wondering), and umbrellas are out of scope anyway (since PAYE is being applied). It's really a contractual issue....

[jamesbrown]

What's your affiliation with these potential scammers? If none, then consider yourself previously naïve and now fully aware that your involvement with such a scheme would be A Very Bad Idea™....