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CIS for cleaning work?

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One of my clients, who runs a cleaning business, has informed me that she has had to register for CIS to carry out some cleaning for a construction company.

The company is renovating some properties which will be sold once completed. My client will go in and clean the properties throughout before they're sold.  I wouldn't have thought this would come under CIS?

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By williams lester accountants
07th Sep 2021 12:13

We have a cleaning company client who only do work for construction companies either on new builds or refurbs, they are CIS registered and are deducted CIS on the appropriate jobs. They have been in CIS and operated this way for over 10 years.

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By rmillaree
07th Sep 2021 12:58

" she has informed me that she has had to register for CIS to carry out some cleaning for a construction company.
I wouldn't have thought this would come under CIS?"

If its labour being provided for any type of construction type work (including residential) its much safer to presume it will probably come within cis and work back from there rather than presuming it won't !!!. Doing anything else is very dangerous.

always use the following link as your friend and you shouldnt go too far wrong.
https://www.gov.uk/hmrc-internal-manuals/construction-industry-scheme-re...

As with alot of stuff cleaning depends on the exact details - but is certainly the case that there is no blanket exemption for cleaning so potentially teh work is within teh scope of cis unless it meets the criteria whereby it is excluded!!. from what you have posted unless its external cleaning its likely to deffo be within cis.

https://www.gov.uk/hmrc-internal-manuals/construction-industry-scheme-re...

FA04/S74 (2)(d) states that the following operation is within the scope of the Construction Industry Scheme

‘internal cleaning of buildings and structures, so far as carried out in the course of their construction, alteration, repair, extension or restoration’.

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Replying to rmillaree:
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By legerman
07th Sep 2021 13:21

rmillaree wrote:

" she has informed me that she has had to register for CIS to carry out some cleaning for a construction company.
I wouldn't have thought this would come under CIS?"

If its labour being provided for any type of construction type work (including residential) its much safer to presume it will probably come within cis and work back from there rather than presuming it won't !!!. Doing anything else is very dangerous.

always use the following link as your friend and you shouldnt go too far wrong.
https://www.gov.uk/hmrc-internal-manuals/construction-industry-scheme-re...

As with alot of stuff cleaning depends on the exact details - but is certainly the case that there is no blanket exemption for cleaning so potentially teh work is within teh scope of cis unless it meets the criteria whereby it is excluded!!. from what you have posted unless its external cleaning its likely to deffo be within cis.

https://www.gov.uk/hmrc-internal-manuals/construction-industry-scheme-re...

FA04/S74 (2)(d) states that the following operation is within the scope of the Construction Industry Scheme

‘internal cleaning of buildings and structures, so far as carried out in the course of their construction, alteration, repair, extension or restoration’.

Thanks for your detailed response. From reading that, if the property has been renovated, then cleaning undertaken so it can be put up for sale, then it's cis. Any cleaning after that is outside of scope? I think you're right that it's more than likely CIS.

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Replying to legerman:
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By rmillaree
07th Sep 2021 15:07

" From reading that, if the property has been renovated, then cleaning undertaken so it can be put up for sale, then it's cis. Any cleaning after that is outside of scope? "

Pretty much yes - it seems to be saying up to and including the point the "construction operations" are fully completed it is within cis. After that point construction is completed so it morphs to maintenance work which is non cis. Note the building may still be held for resale at this point by the builder so it may potentially be tricky to work out whether construction has been fully completed or not unless its explicitly confirmed by the builder/customer who knows where they are in that regard. Note you always want to watch out for mixed contracts too - if its part cis and part non cis its possible/probable the whole work could be brought within cis due to the fact a part of the contract comes within cis.

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By libraBE
15th Sep 2021 17:40

Hello, we had a similar client .... before drc, cis was due on cleaning during building work, and work was zero rated, but cleaning of completed homes, that got grubby during viewings, and cleaning of any show homes were all vatable and non-cis, as that was then general services, not construction.
Never had to review this under Drc, but knowing if the cleaners' bills are going to the end user, or not, should determine vat.

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