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Consultation on off-payroll working in the private sector launched

Off-payroll working in the private sector launched

The Government’s long awaited consultation on off-payroll working in the private sector was launched on 18 May.

Colin Ben-Nathan


KPMG in the UK


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The consultation

The Government’s long-awaited consultation on off-payroll working in the private sector was published by HMT and HMRC today.Responses are due by 10 August 2018.

The proposals

Perhaps unsurprisingly, the Government's lead option is to extend the recent public sector reforms into the private sector, with a focus on identifying any ways in which the reform and implementation process may be improved upon in future.

However, alternative approaches have also been put forward:

  • Encouraging or requiring businesses to ensure ‘IR 35’ compliance in their labour supply chains, complementing recommendations made by Sir David Metcalf in his recent Labour Market Enforcement Strategy report; and
  • Applying more stringent record-keeping requirements on businesses who make payments to off-payroll workers, thereby supporting HMRC’s compliance activity.  

The Government feels, however, that both options continue to leave open opportunities for non-compliance and, indeed, we think that it may therefore be a challenge for respondents to the consultation to overcome this point of view.

The implementation date remains unconfirmed. However, the consultation document acknowledges that more time would have been preferred ahead of the measures going live in the public sector last April.

We might therefore expect April 2020 to be the likely implementation date for these measures.

Our view

Clearly, there is much for the private sector to consider, and it is important for business to contribute to the debate on off-payroll working. Our experience working with public sector organisations has shown that comprehensive preparation for the new measures will be vital to support compliance in future.

KPMG will be responding to this consultation, and will be holding events to discuss the Government’s proposals.

If you have any comments that you would like us to consider as part of our submission to HMRC, please get in touch with Colin Ben-Nathan, Mike Lavan or your usual KPMG contact. If you would like to be added to the invitation list for one of our seminars or other events, please email us

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