ICAEW responds to proposed travel & subs changes.

[Michael at BI Accountancy]

Not sure if this has already been mentioned.

Can see this being a good eye opener for HMRC...

Proposed tax changes for workers supplied by intermediaries are premature and unnecessary

http://www.icaew.com/~/media/corpora...bsistence.ashx

[jamesbrown]

Thanks for the links. Probably better in "The Future of Contracting" subforum. One thing I noticed in their response to the IR35 discussion was the following:

"This response of 2 October 2015..."

I hope they cleared that w/ HMRC first The deadline was 30 September.

[jamesbrown]

I'll also add that the IR35 response is great; they raise some seriously good, practical, points w/r to operating these proposals in the context of RTI etc.

[Zero Liability]

I'll also add that the IR35 response is great; they raise some seriously good, practical, points w/r to operating these proposals in the context of RTI etc.

Yeah, just read it. Really great stuff. I'd go so far as to say that it leaves their entire case in tatters, but they can always choose to ignore. The problem, however, with doing that is that the ICAEW interfaces directly with big business and so is not likely to be so easy to simply brush aside. Lets hope the date isn't used as the pretext. I think with the responses put forward by Lisa et al, IPSE, AbbeyTax and ICAEW on both fronts virtually all major ground has been covered, with more sensible alternatives proposed and the problems of their current approach laid bare.

[mudskipper]

Good stuff - thanks!

[jamesbrown]

Yeah, just read it. Really great stuff. I'd go so far as to say that it leaves their entire case in tatters, but they can always choose to ignore. The problem, however, with doing that is that the ICAEW interfaces directly with big business and so is not likely to be so easy to simply brush aside. Lets hope the date isn't used as the pretext. I think with the responses put forward by Lisa et al, IPSE, AbbeyTax and ICAEW on both fronts virtually all major ground has been covered, with more sensible alternatives proposed and the problems of their current approach laid bare.

Yeah. It's definitely one of the best responses I've read, because it addresses some of the implementation details that should give HMRC serious cause for concern; and, yes, I do believe they're stupid enough to have put this out for discussion without proper consideration of their ability to implement something in practice.

[Michael at BI Accountancy]

Thanks for the links. Probably better in "The Future of Contracting" subforum. One thing I noticed in their response to the IR35 discussion was the following:

"This response of 2 October 2015..."

I hope they cleared that w/ HMRC first The deadline was 30 September.

the date did not even cross my mind!

bar the date they have supplied, the points raised are really good.

ICAEW do also tend to have great pulling power when it comes to telling HMRC they are completely clueless!

[LisaContractorUmbrella]

Really good response but I am surprised that they suggested putting the tax liability with the agency, rather than the end client, in the even of non-compliance; surely the only party able to determine whether or not there will be SDC is the person who will be doing the S'ing, D'ing and C'ing?

[Zero Liability]

Really good response but I am surprised that they suggested putting the tax liability with the agency, rather than the end client, in the even of non-compliance; surely the only party able to determine whether or not there will be SDC is the person who will be doing the S'ing, D'ing and C'ing?

This one also surprised me:

23. We suggest that consideration be given to expanding the quarterly intermediaries reports to cover whether SDC is being exercised and, if feasible in the context of the arrangements, to
quantify travel and subsistence claims.

Don't see how agencies or even end clients would necessarily be well positioned to tick a box to that effect, especially given all the arguments made in the same piece against the feasibility of such a determination by the end client, nevermind the agency.

[LisaContractorUmbrella]

This one also surprised me:



Don't see how agencies or even end clients would necessarily be well positioned to tick a box to that effect, especially given all the arguments made in the same piece against the feasibility of such a determination by the end client, nevermind the agency.

I suppose a box ticking exercise gives HMRC a place to start