Readers’ forum: IR35 responsibilities

We act for a small limited company client that has gangs of labour who are all under the construction industry scheme (CIS) regime. Their client is a large multinational which with the new IR35 rules coming online is advising businesses working for it that from 6 April 2020 it will no longer engage with limited companies or personal service companies off-payroll whether directly or through agencies or intermediaries. Instead if they are to continue providing services to it all contingent workers will have to register and be paid under PAYE through an approved employment agency. If this requirement is not followed the multinational may serve notice to terminate the engagement in accordance with the provisions in their contract.

The multinational has advised agencies providing workers that a letter to this effect has been sent to workers and that the agency should...