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Do as I say, not as I do?

HMRC tells employers they are responsible for "applying supply chain due diligence principles"

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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

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?

Replies (4)

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A Putey FACA
By Arthur Putey
14th May 2021 16:48

The joke here is that the "employers" in question are the MUCs. It is the upstream contractors that are actually at fault .... all the way up to the government.

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Replying to Arthur Putey:
By Hugo Fair
14th May 2021 17:20

Actually the joke is worse ... in that the govt contracted G4S who contracted HR GO who contracted thousand of MUCs - which is my definition of a "supply chain".

But in whichever direction the brown stuff flows along the supply chain, my point is that HMRC are preaching guidelines (to us and our clients) that contain suggested rules which, although commonsensical, were patently not followed by the govt.

Thanks (2)
By Paul Crowley
14th May 2021 18:40

Perhaps the chain than caused this will be deregistered
HMRC claim to have done that 22,000 times already

HMRC can steal your company is what HMRC is claiming.
Be nice if they listed them
Much smaller job than listing employers that furlough.

Thanks (1)
By Rgab1947
24th May 2021 09:29

Why does HMRC not write the contracts for us. they are legally trained are they not? And they are responsible for our P&L, are they not? And are we not living in China/Belaruss/Rusia/North Korea.?

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