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12 steps to Off-Payroll (IR35) compliance

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12 steps to Off-Payroll (IR35) compliance

By Dave Chaplin is CEO of contracting authority ContractorCalculator and  IR35 Shield.

Recently, we have seen a rush of companies, notably in the financial services sector, set out plans to phase out their use of self-employed workers who operate via limited companies in the light of the looming new Off-Payroll tax legislation that is due to hit the private sector in April 2020.

The reforms have certainly prompted firms to reconsider how they engage with their workforce and some have discovered instances where they had long-term contractors working with them who have been happy to convert to full-time employment.

However, the banks are a very special case because they cannot reclaim much of the VAT that is charged to them by contractors. So, by putting them on payroll, they can potentially save the VAT, and can use that to pay the extra employment taxes that are due under the new reforms – which is actually less than the VAT.  For those firms that are unable to offset VAT, this strategy isn’t available to them.

For the changes in banking, the overall effect on the Treasury is likely to be a reduction in tax take, particularly because banks are offering reduced rates, typically cuts of 25%, in conjunction with the changes – but policymakers are blind to this.  The effect on the hiring firms will see them struggling to hire the top talent and skills they need for projects and, in instances where they need highly sought-after skills, they will undoubtedly discover that hiring contractors on payroll will cost them significantly more. Rate rises for in-demand contractors will be inevitable as the flexible workforce shrinks as part of its rebalancing.

Decisions made by the global banks could be seen to be a kneejerk response to legislation that they simply do not know how to navigate and we have seen other firms take blanket ban decisions to not engage contractors – whilst this could be considered an overly cautious approach, for them it’s more of a strategic one and makes some sense.

Off-Payroll compliance will prove crucial to a company’s continued engagement of contractors, who will naturally seek engagements where they can secure a fair and accurate IR35 status assessment, creating the opportunity for an ‘outside IR35’ contract.

A diligent, structured approach to compliance not only mitigates risk and appeases contractors, it also minimises the administrative and cost burden of complying with the rules.  Here isa four-stage, 12-step strategy enabling companies to achieve exactly this.

Stage 1: Identify

Step 1: Collate

Depending on the size of a firm’s contingent workforce, the burden of assessing each contractor for IR35 might seem daunting. But only contractors trading via a limited company need to be considered under the Off-Payroll rules – this could be a small portion of the workforce. To find out, we advise that clients send a spreadsheet to their recruitment partners to complete, detailing the operating structure used by each contractor.

Step 2: Explore

Meanwhile, evaluate your contractors and group together those who have similar contract templates or working conditions. At this stage, your chosen Off-Payroll compliance solution or provider should help identify those who may pose a significant IR35 risk and inform on whether it’s practical to change the working conditions in some cases to mitigate IR35 risk across your workforce.

Step 3: Segment

Having undertaken the previous two tasks, and having received completed spreadsheets from your recruitment partners, you’ll now know the size of the task at hand. For example, if the majority of contractors posing a high IR35 risk are engaged via umbrella companies, your compliance burden will be far smaller than if most operate via limited companies.

Step 4: Assess

Your next step is to assess your affected contractors for IR35. An IR35 assessment requires the assistance of a compliance solution or provider, and needs to gather information from the contract paperwork, the working conditions and the contractor’s details. Ideally, you’ll want to address individual areas of the assessment to the relevant parties, to ensure accurate assessments while sharing the compliance workload.

Stage 2: Analyse

Step 5: Risk profiling

The Off-Payroll rules also require hirers and their recruitment partners to police their contractor supply chains. This is due to the liability transfer provisions, which permit HMRC to pursue hirers and agencies for unpaid tax in the event that another intermediary has been non-compliant. Many tax avoidance schemes operate under the guise of ‘umbrella companies’, so beware of intermediaries with no professional accreditations, or whom market information suggests may be dodgy.

Step 6: Modelling

Conducting status assessments will help you to find answers to a number of critical questions, such as:

  • What is the accumulative employment tax liability for ‘inside IR35’ contractors?
  • What status factors are common across the firm, causing risk?
  • What projects are at most risk?

Answering these questions will help inform a sound strategy to mitigate any damaging financial impact posed by the Off-Payroll rules.

Stage 3: Plan

Step 7: Engagement 

The Off-Payroll rules will cause many companies to review their engagement options. One reason is because direct engagement of contractors deemed ‘employed for tax purposes’ creates a heightened risk of employment rights claims. Clients may seek to insert intermediaries into the arrangement to mitigate this risk, at which point they will need to consider their chosen model of engagement.

Step 8: Policies 

Having considered some of the previous steps, you will now be well placed to establish some policies for the supply and engagement of contractors going forward. For example, you might ask yourself:

  • Should ‘inside IR35’ contractors be allowed to contract via limited companies?
  • Should we restrict the umbrella providers that contractors can operate through?

Step 9: Finance

Similarly, having conducted some financial modelling, you will now be ready to establish a financial plan for your workforce. This might involve exploring potential legitimate policy changes in working practices to secure the ‘outside IR35’ status of contractors. Where this isn’t possible, depending on your budget, you may need to make some big decisions, such as:

  • Which contractors will be difficult to retain ‘inside IR35’?
  • How much would it cost to retain key individuals?

A financial plan will help you to prioritise expenditure to ensure that projects continue to run as smoothly as possible.

Stage 4: Implement

Step 10: Communication

Communication with contractors is critical. Speak to those deemed within scope of IR35 in groups to establish what their plans are. Making it clear that you have conducted a considered IR35 status assessment may mean that some are more inclined to continue working for you. In turn, their feedback will help you update and refine your strategy accordingly.

Those who are leaving will require termination notices. You will also need to serve termination notices to ‘inside IR35’ contractors who are staying, before offering them an alternative method of working. Also, make sure all outstanding invoices are paid. All of this needs to be achieved by the end of March 2020.

Step 11: Alignment

You must communicate policies established in step eight to your recruitment partners, as they will play a crucial role in implementing them. As well as explaining your plans, you will need to establish a deadline. We recommend allowing at least a month’s notice, to give recruiters time to notify suppliers that aren’t on your Preferred Supplier List (PSL).

Step 12: Monitor

Sustained monitoring of your workforce is key to compliance, to ensure that working practices continue to reflect the written agreement, negating any potential IR35 risk. Each contract renewal should be accompanied by a new status assessment. Similarly, keep an eye out for analysis of the latest IR35 court cases. Some may set future precedents impacting employment status case law, which could affect your current workforce.

The benefits of structured Off-Payroll compliance

Compliance with the Off-Payroll rules is not only a legislative requirement, but also key to the continued engagement of valuable contractors. Implementing these 12 steps will help ensure continued compliance with the Off-Payroll rules, while minimising the associated workload in the long-term.

Finance

The potential of Open Finance and the digitisation of tax records

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The potential of Open Finance and the digitisation of tax records 1

By Sudesh Sud, Founder of APARI 

The world is undergoing huge changes at the moment. Between coronavirus pushing the economy to the limit and a group of Redditors challenging the financial market hegemony, people are questioning the role of established institutions. If finance doesn’t work to enable the economy, businesses or individuals, then who is it for?

Before the digital revolution, financial experts were seen as a necessity. They knew how things worked, what everything meant, could provide good advice and were employed to sit at the heart of the action. Now, trading can be done by anyone online through established platforms, with a wealth of information available to hand.

Yet, as the 2008 financial crisis proved, established financial institutions have made themselves too big to fail. Simply tearing down the existing financial system would leave many ordinary people, along with businesses and government treasuries, in ruin.

However, as legendary futurologist, Buckminster Fuller, once said: “You never change things by fighting the existing reality. To change something, build a new model that makes the existing model obsolete.”

Traditional banking models are already being upended by technology. Through Open Banking, challenger banks are able to connect services digitally, cutting inefficiencies and costs while speeding up transactions. Now, Open Finance is seeking to build on this model to connect financial services via technology, potentially making the existing financial model obsolete.

Just as Open Banking led to greater democratisation of money, Open Finance has the potential to transfer power back to individuals. Not only would this benefit society as a whole, but it would help minimise the boom-bust cycles that cripple entire economies. No individual would be too big to fail, and bailing people out would cost far less, having minimal impact on the economy overall.

With more information available to them, Open Finance businesses will be able to use technology to make better decisions instantly. Many people struggle to get onto the housing ladder due to a poor credit score, for example, yet they have been paying rent every month of their adult lives. Why, then, can they not access mortgages? A company called Credit Ladder is addressing this through Open Banking, reporting rent payments via challenger banks like Starling to credit agencies, helping good renters to access mortgages.

While it is still very early days for Open Finance, there seems to be an endless raft of possibilities to benefit individuals, businesses and national economies. Faster, more secure, and less risky access to credit can help grow the economy, transforming finance from something that benefits a few wealthy capitalists to something that enables growth in the real economy.

So how else could Open Finance benefit society?

Using Tax Information

Every working adult pays income tax. Some of us via self-assessment while others are enrolled in PAYE. Regardless, we all have tax records with a wealth of financial information that has been verified, at least in part, by HMRC.

This centralised repository of financial information could be put to better use, such as allowing credit reference agencies to better understand an individual’s risk profile or helping to prove income as part of a mortgage application. Unfortunately, HMRC is a black hole of information ‒ its sheer size and power sucks information in, but nothing comes back out again.

However, by Making Tax Digital (MTD), HMRC are effectively allowing individuals to keep validated tax records on the software of their choice. Software providers may then be able to use this information to enable certain aspects of Open Finance. The information doesn’t need to be protected by HMRC, it is the individual’s choice and responsibility over how to use their own information.

As MTD software develops, we will see it connected to Open Banking, allowing self-assessed taxpayers to connect their business account directly to the software, effectively getting their tax return completed for them by an AI program. They would simply check the details, add any adjustments, and click submit. HMRC would then validate the records, providing assurance for any financial institutions using that financial information.

More Growth, Lower Risk

With access to complete and validated financial information, lenders would be able to more quickly and accurately assess individual risk when considering a loan or mortgage application. This would greatly speed up the process of applying for a loan, whether for a business venture or property purchase, for example.

Take residential landlords, for example. They may own a few properties already, with equity coming out of their ears. If that landlord wants to obtain another property, they would need to get their accountant to assemble their financial information, complete a SA302, and send everything off to their mortgage advisors who would then validate the information before submitting the mortgage application.

The application can then take months to approve, slowing down the process and potentially leading to missed opportunities. Since property sales usually occur in a chain (the owner of the property you are purchasing is usually purchasing another property, and so on), these inefficiencies slow the process down for everyone and can have major impacts.

If, however, mortgage applicants could simply share validated financial/tax records, mortgage providers could use that information to make quick decisions with reduced risk. What’s more, applicants could share only relevant, high-level information, rather than expose their entire financial history.

Individual Risk Management

Currently, individuals can manage their credit score/risk profile via third party providers like Experian, Equifax and TransUnion. These credit reporting agencies use limited information, such as credit cards, store cards and loans to assess risk. Individuals need to understand what factors each agency uses in order to ‘game’ the system.

For example, someone who has always been careful with their money, kept to a strict budget and never taken out a loan or credit card will have a far worse credit rating than someone who regularly uses debt to finance their lifestyle. So, even though they may have amassed a good deal of savings, they cannot get a good deal on a loan or mortgage.

With Open Finance, these individuals would be able to quickly prove their earnings, spending, and savings, decreasing their risk profile in line with reality. Rather than crude measures of creditworthiness, financial institutions would be able to use accurate and validated information to make quick decisions based on realistic risk. This both transfers more power to individuals and contributes to faster growth while reducing overall risk.

As a centralised repository for validated financial information, MTD providers will be in a unique position to develop a two-sided marketplace for finance, allowing credit providers to match products to individuals’ risk profiles. When a customer needs a loan, credit card or mortgage, they can simply browse products for which they have already been approved, applying and receiving finance instantly.

Empowering PAYE Taxpayers

Currently, PAYE taxpayers have little, if any, visibility or control over their tax contributions. They will see the amount paid in tax and national insurance, but to claim any allowances requires them to submit a self-assessment tax return. For most PAYE taxpayers, this simply doesn’t seem worthwhile.

Yet, self-employed taxpayers can claim for things like travel to their place of work, a proportion of living expenses when working from home, even their lunch. These things are necessary for productive work yet, for PAYE taxpayers, come out of their already taxed income. Meanwhile, businesses tend to make use of every tax allowance available to them.

This imbalance could be rectified with Open Finance connected to tax software. As MTD becomes a validated system for self-assessed taxpayers, a new version could be developed for PAYE taxpayers, putting them in control of their tax and finances. Not only would they be able to benefit from Open Finance in the same way as self-assessed taxpayers, but they will also be able to claim for reasonable allowances. What’s more, HMRC/the Treasury/the government would be able to hold employers accountable for pay disparities and unreasonable tax avoidance.

Open Finance, then, has the power to speed up and reduce the cost of obtaining and providing finance. It would make the finance system fairer and most transparent while distributing financial power, and help to avoid the creation of too big to fail financial institutions and the boom-bust cycle that has become unfortunate features of modern capitalism.

Ultimately, Open Finance has the potential to help the UK and other nations recover from the seemingly unending series of crises that have plagued the early 21st century by allowing people to access finance quicker in order to grow their business and personal finances while reducing risk, inefficiencies, and costs.

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Finance

Three ways payment orchestration improves financial reconciliation

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Knowing the best alternative payment methods

By Brian Coburn, CEO or Bridge,

When Luca Pacioli, the 15th century Venetian monk, invented double-entry account keeping, managing financial reconciliations had its own unique challenges. The father of modern accounting didn’t have to deal with glitches in his book-keeping app but he did have to write with feather-based quills by candlelight. Five hundred years later the challenges are different but no less onerous.

As in the 15th century, solid financial reporting is at the heart of every successful high-transaction business. As Pacioli no doubt knew, up-to-date, well-documented accounting ensures good operational health and makes it easier to grow. And that’s never been more important.

While it might not be feather quills by moonlight, today’s environment of multiple customer channels can be time-consuming and labour intensive, with various payment methods and financial reconciliations from multiple data sources.

Understanding cash inflow through online transactions is a critical element of financial reporting. However, when these involve multiple payment processors and payment methods and a complex system of disjointed silos of payment data, this can become a cumbersome and arduous manual task.

Common issues in this fragmented payments landscape include working across different formats, managing different data owners and access as well as inconsistent process timings. The result is often increased inaccuracy and inefficiency. Procuring multiple tools and software can end up being uncost-effective and unwieldy. Though the current digital transformation is an exciting time for retailers, staying on top of the ever-changing payment options can be an overwhelming burden for many business owners.

Introducing payment orchestration presents a single, accessible, creative and accurate source of transactional data, crucial for today’s complex challenges around financial reconciliations.

Simplicity

Today, commerce is 24/7, so being able to access and analyse real-time information is vital to managing business controls. Many organisations have looked to automate these processes with account reconciliation software.

However, one key challenge is the sheer volume of transactions and the need to capture data from a variety of different sources. Payment orchestration enables transactions to be carried out by multiple payment processors and payment methods with simple and flexible plugins, centrally monitored and routed in the most optimum way.

It allows users to add or remove providers easily, knowing the complexity (detecting outages and automatically rerouting payments) is being handled by a trusted specialist partner via an intelligent platform.

Bringing disparate sources of online transaction data into one place simplifies how enterprises access and operate with multiple payment processors and payment methods. This makes it easier for businesses to remain agile.

Speed

For organisations that still depend on manual, spreadsheet driven processes, the mechanics of reconciliation can be extremely time consuming.

A payment orchestration layer creates the opportunity to automate processes and reduce manual intervention. By bringing multiple payment processors and payment methods into an integrated service layer with intelligent routing capabilities, the impact of individual outages or failed payments can be mitigated to ensure optimum payment success rates, saving crucial revenue.

Accuracy

Naturally, significant manual work brings with it the added risk of human error. The speed with which business moves today demands accurate accounting processes. Checking for error takes up valuable time that could be spent focusing on business growth.

Payment orchestration can improve accuracy and reduce the opportunity for error. Providing a holistic and central source of real-time transactional data, payment orchestration can offer improved transparency and greater visibility of financial data.

With all transactional data captured in one source, payment orchestration can present a data source to feed other applications – such as automated reconciliation tools and fraud management – automating business processes in a seamless way across the enterprise. Good practice like this will, of course, enable a consistent approach to fraud management across all channels and payment services.

Multiple payment choices can be onerous but, today, not adopting them at all is unwise. The key to success, and good financial reconciliation, is being able to streamline and manage them.

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Finance

Circular Economy must be top of the business agenda in 2021

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Circular Economy must be top of the business agenda in 2021 2

By Andrew Sharp, CEO of CDSL, the UK’s leading appliance spare parts distributor

The last year has been one in which we were all forced to change our behaviour. We have become far more familiar with the four walls of our home than we would have liked, we have had to give up the social activities that mean the most to us and we have spent much longer apart from relatives than we could have imagined.

But alongside the many reluctant changes that we have made, there have been some silver linings. Both consumers and businesses have reassessed their priorities, and we have seen a noticeable increase in the importance of sustainability and social value in everything we do.

Within this has been a rise in awareness of the power of the circular economy. Research from the Recycle Now campaign shows nearly nine out of 10 UK households now say they “regularly recycle” (September, 2020), while environmental organization Hubbub found that 43% of people are more concerned about plastic pollution than before Covid-19 (September, 2020).

The role of the circular economy in underpinning wider sustainability targets is now being widely realised by Government, consumers and businesses alike. The Ellen MacArthur Foundation recently found that circular economy policies contribute towards tackling the remaining 45% if greenhouse emissions that cannot be resolved by transitioning to renewable energy alone (January, 2021), and the circular economy can offer solutions to the 90% of biodiversity loss and water stress that traditional resource extraction and processing require.

However, reducing the impact of our current linear economy will require widespread change and every product that we use will need to be accommodated within this. One area that is yet to be fully incorporated into a circular economy model is e-waste – an area where the UK is unfortunately a world leader. Other than Norway, the UN has said that the average person in Britain discards more electrical items each year than anywhere else in the world, and the UK is also the worst offender in Europe for illegally exporting toxic electronic waste to developing countries.

1,000,000 tonnes of e-waste are produced annually in the UK, enough to fill six Wembley Stadiums. The WEEE Forum estimates that only 17.4% of e-waste was recycled in 2019 (October, 2020), meaning the vast majority of this is burnt or thrown into landfill, creating environmental hazards for years to come.

However, the good news is that 100,000 tonnes of e-waste would be avoided if we fixed just 10% more perfectly repairable appliances. As an electrical spare parts retailer, we have seen incredibly encouraging trends throughout 2020. Our leading consumer brand eSpares has seen record-breaking surges in demand over the past year as consumers look to fix appliances themselves rather than kicking them to the kerb.

We recently conducted a survey of 5,000 people and the results clearly show this growing interest among young people for repairing and recycling their electrical goods. The answers suggest that three times more young people than over-65s would try to fix a broken appliance at home and that the environmentally conscious under-35s are increasingly keen to fix gadgets rather than throw them away.

That is why we have taken steps to encourage our customers to drive a circular economy throughout the year with the campaign #FixFirst. As a business and a retailer, it is our responsibility to help educate our customers on the benefits of a circular economy. Free services like our Advice Centre, which has over 700 step-by-step articles and attracted 1.2million visits in 2020, contribute to this by offering assistance on making repairs around the home whenever and wherever it is needed.

It is up to businesses to ensure that we champion the benefits of the circular economy and ensure these behaviours are maintained permanently.

Certain sectors are already leading the charge in doing this. In fashion retail for example, Levi’s is paying consumers to bring back old pairs of jeans for sale on a second-hand marketplace. Patagonia similarly will take back old pieces of clothing to repair and refurbish them.

Plastic packaging is also receiving some tough attention from across the retail and food and drink manufacturing sectors. Tesco has announced that it has removed one billion pieces of plastic from its UK business in just one year through a policy of Remove, Reduce, Reuse and Recycle, while consumer brands like Nestle for example are testing reusable packaging to reduce the amount of single use plastics.

Consumer attitudes are moving in one direction on the topic of the circular economy and it is therefore essential that businesses also get ahead of this as a commercial priority. In 2020, Deloitte found that 43% of consumers were already actively choosing brands due to their environmental values, while 2/3 of consumers have reduced their usage of single use plastics. In direct to consumer in sectors like the one in which we operate, sustainability credentials are fast becoming a purchasing priority alongside price.

Legislation in the UK is also increasingly clamping down on businesses that do not champion circular economy in the products they create and use. The Environment Bill that is expected to be passed in Autumn will give Government powers to introduce new targets on waste reduction and packaging. Extended Producer Responsibility expected to be introduced in 2023 will also lead to major fees for manufacturers of products that cannot easily be recycled.

As the circular economy rises in priority over the next year, businesses must act fast. Robust policies on the circular economy will both drive environmental benefit and allow businesses to stay ahead of a trend that is fast becoming a priority for consumers.

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