IR35 – Journey to April 2021

Access our new ‘Off payroll workers webpage’ here.

What can you find on these IR35 pages?

We will continually share Deloitte’s latest insight, key updates and solutions as we move towards 6 April 2021, the deferred introduction date for the new rules.

The late deferral of the reform, coupled with the disruption caused by the COVID-19 pandemic, has left organisations which engage with off-payroll workers at different stages of readiness for IR35, as we move towards the new implementation date of 6 April 2021. The content we are sharing is valuable for all organisations preparing for the changes, whether they are at an early stage of their preparation or recommencing pre-6 April 2020 IR35 work/projects, or whether they that have already implemented the plans they had developed before 6 April 2020 to operate IR35 “business as usual” processes going forward.

A newly introduced IR35 readiness framework (click IR35 readiness framework button above), which outlines the key phases of preparation for organisations at different stages of their preparation, through to operating successfully in a business as usual.

One key challenge that organisations have faced in their preparations to date is developing a robust methodology for making status assessments. Our IR35 Status Assessment page shares our perspective on this, as well as learning points from pre-6 April 2020 preparations. It also draws on our experience of HMRC’s approach to the equivalent IR35 public sector rules. It includes FAQs on topics such as status assessment tools, how to resolve ‘undetermined’ or complex cases, and how organisations should be focusing on a methodology which supports a review of an incumbent population, but also considers how to manage future “business as usual” compliance.

To complement our bespoke advice, we have developed technology solutions to support organisations in identifying off-payroll workers and managing the assessment process as part of their wider resourcing and on-boarding strategy. These are innovative, dynamic tools designed to assist all organisations engaging with off-payroll workers, but particularly those where there are high numbers of contractors, or where distinguishing individuals engaged via Personal Service Companies from other contractors may be challenging.

We have collated some further materials, including relevant HMRC publications, draft law and recordings of webinars and short videos we have prepared. This is an essential compendium of knowledge and resource for anyone tackling the IR35 rule changes.

Our IR35 key actions: explained page contains short videos exploring some key IR35 readiness actions.

We will also provide our perspective on any updates from HMRC and on the legislative process.

Recent updates

How can Deloitte help?

We can help you prepare for all aspects of the IR35 changes, including:

• Working with your project team of key stakeholders to ensure you lay the best possible foundations, i.e. that you identify the key process steps and decisions which will need to be taken to effectively manage the change. This could begin by holding a facilitated workshop.
  
• Using automation techniques prepared to identify PSCs with whom the business engages.
  
• Managing the employment status assessment process and using our workflow solution to streamline communications and maintain an audit trail of discussions.
  
• Drafting communications to collective/specific stakeholders, including impacted PSCs.
  
• Considering contractual amendments with both PSCs and agencies you use to support with the transition to the new rules.
  
• Designing new processes and controls to manage the operational impact of the changes, e.g. payroll.
  
• Support with the Status Disagreement Process.
  
• Supporting end-to-end project management on all of the above.