Action needed to comply with April 2021 IR35 Changes
If you are an individual or your business engages an individual, and payment is not
made to the individual under PAYE, and the individual works through a PSC
or other intermediary, both the individual and its business client should have checked well before 6 April 2021 to see whether the April 2021 changes reduce payments to the individual,
increase the administration work or costs of either party, cause practical
difficulties or give rise to any other commercial or financial impact.
Where individuals are engaged by you without operating PAYE for them as employees, you should have identified all such
individuals working for you through PSCs or other intermediaries, and the
whole labour supply chain. You then needed to determine those individuals’
If you are an individual operating a PSC, you should already have talked to your business
clients and any intermediaries about their implementation of the 2021 rules. You might be able to use your PSC for some clients but not others.
In all cases you should have looked at the rules and their impact on your
net income. You should have checked whether your clients are actually prepared to deal with you through a PSC at all, and whether if
they are, they are altering the rates they pay your PSC to reflect the
impact on those clients of the 2021 changes. Where any clients decide not
to engage your PSC, it does not follow that they then engage you as a
self-employed individual: they might only be prepared instead to engage you
as an employee, and, if so, you need to consider the pay rate and
other terms that they offer to you.
We recommend that you seek advice and guidance from suitable advisers or
sources. Some firms offer IR35 services as to the impact on you of the 2021 changes.
See the Guidance Note for further details of the above.