My client provides consultancy services to various clients, some of which are "medium" and "large" for the purposes of the off-payroll legislation.
She expects the engagements to fall outside IR35 and for this to be reflected in the determination from her client.
From time to time, she engages a substitute to send in her place. The substitute invoices (via his PSC) to my client's PSC. Is my client required to issue a determination to the subsitute under the off-payroll legislation (because the end-client is a medium or large company)? Or, in this case, is my client the "end-client" and is exempt from the off-payroll rules by virtue of being a "small" company?
I fear I am getting myself into a muddle with this one! Would just like some clarification on where the responsibility for issuing determinations lies..