I wonder if any re-review with guidance from HMRC will also uncover contracts blanket deemed inside that should be outside. I won't hold my breath on that.
At least the retrospective aspect of active contracts is being covered in that the change of status doesn't affect the contract prior to the new review date due to 'new guidance' from HMRC, so a new contract is offered to differentiate between the old and new status.
Seems fair to me, hopefully they're learning from the fallout of the loan charge retrospective action, and fits with the conceptual practice of not needing to apply a status change mid contract (causing retrospective tax for the period prior to the change) as the contract is terminated and a new one issued.
I wonder if any changes to CEST would also trigger a re-review situation (otherwise what is this 'new guidance'?), and if so how often HMRC are changing CEST to create more work and uncertainty amongst those using it for the initial status determination.
At least the retrospective aspect of active contracts is being covered in that the change of status doesn't affect the contract prior to the new review date due to 'new guidance' from HMRC, so a new contract is offered to differentiate between the old and new status.
Seems fair to me, hopefully they're learning from the fallout of the loan charge retrospective action, and fits with the conceptual practice of not needing to apply a status change mid contract (causing retrospective tax for the period prior to the change) as the contract is terminated and a new one issued.
I wonder if any changes to CEST would also trigger a re-review situation (otherwise what is this 'new guidance'?), and if so how often HMRC are changing CEST to create more work and uncertainty amongst those using it for the initial status determination.
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