On the back of the MUC stories in the press generated by HMRC over the last few days, they've updated their guidance to employers at https://www.gov.uk/government/publications/use-of-labour-providers/advic...
Aside of the unlikelihood of this 10 pages being read / understood / applied by the average harassed business owner(s), the cheek is astounding in that the "Guidelines to help you check, act and review" specifically include consideration of:
* adding a clause to the contract requiring your authorisation before further sub-contracting to a third party, and check that this is adhered to;
* adding a clause in the contract stopping the use of off-shore intermediaries; and
* whether the workforce has been repositioned into ‘mini umbrella companies’ to enable fraudulent abuse of government incentives aimed at small businesses (such as the VAT Flat Rate Scheme and Employment Allowance).
Now if this was described as "lessons learned" or as new rules for "public sector contracts", then it would at least be (belated) recognition of the problem ... but to position it all instead as a set of further burdens on the general private sector is mind blowing/boggling (choose your preferred generational epithet)!
If anyone has the time to read the Guidelines, I'd be interested to hear how you think your clients will react to be being told that HMRC want them to read and inwardly digest it all?