The Government has published its final proposals for reforming the off-payroll working rules from April 2020 for the Private Sector and while the public sector legislation has fundamentally been mapped across to the private sector, there are some additional changes which Public Authorities will now need to incorporate in how they manage and comply with these new changes.
There are three additional key areas of risk that public bodies will need to consider from April 2020. These are:
The transfer of debt provisions:
We are awaiting further guidance from HMRC on this, however it is clear that Public Authorities will need to undertake appropriate due diligence on their labour supply chain. Public Authorities should look closely at the agencies who supply their contingent workforce and consider what additional provisions should be included in their agency contracts as well as undertaking due diligence on their labour supply chain.
These changes place significant, additional, responsibilities on Public Authorities to ensure increased levels of compliance with effect from April 2020. HMRC have already started to review compliance arrangements within Public Authorities and will expect to see changes in policies and procedures to reflect these new requirements.