The Fizz! Blog

IR35 isn’t being introduced in April

IR35 was introduced in 2000, so it's going to be 21 this year.  In a nutshell, IR35 says that, insofar as your limited company’s revenue comes from you really being a pseudo-employee of an end-client, you can’t use the tax and National Insurance efficiencies of dividends – the company’s got to pay more or less all of that revenue out to you under PAYE.

Simple in theory, a complete failure in practice.  A company’s director had to make the call on whether IR35 applied and whether far more tax and NI should be paid, so there was a big financial incentive to argue they were outside it, and HMRC lacked the resources to police the rules in any meaningful way at all.  And, in any case, the question of what represents an employee-esque relationship is often impossible to answer with certainty.  In the modern world, countless people sit in that grey area somewhere between employment and self-employment.

So, IR35 was to all intents and purposes a failure.  In 2017, the government changed it a little.  If your customer was a public body – an NHS Trust, for example – then the decision was taken out of your hands, and the public body would decide if IR35 applied.  If they decided it did, they’d effectively take your company’s invoice, work out and deduct full employment taxes, and pay whatever remained, to put you more or less on a par with a PAYE employee.  This was effective in one sense – a lot of public bodies did apply the rules in that way – but had the unintended consequence that many of the better contractors just decided to move into the private sector and work there instead.

As a result, the government had a second idea.  From April 2020, those same rules would apply to big private sector companies too – they’d have to make the IR35 call themselves, at their own risk, and if they paid pseudo-employees via a limited company gross then the risk of employment taxes not being paid would be their own risk, not that of the contractor.  This was actually quite effective, and a bunch of big companies stopped using contractors entirely, either putting the workers on to PAYE or just outsourcing that PAYE processing to an umbrella company (technically they could go down that previously described route of deducting employment taxes from your company’s invoice, but there’s no real point, PAYE is an easier way of achieving the same result).

Then COVID happened, and the April 2020 introduction was postponed by a year.  The big companies who’d played ball and got ready for the new world found they could have got away with another 12 months of using contractors.  The big companies who buried their heads in the sand did get away with it.

But the change is still due to come in this April instead, so hopefully those latter companies have removed their heads from the sand and are getting ready to engage with it.  There’s a chance it could be postponed again, of course (the government have form over the last couple of years of very short-notice postponements of changes that businesses have spent a lot of time and money preparing for, even prior to COVID), but it seems unlikely, and it’s clear that it’s being talked about more this time round.  However, what that means is that you do hear a lot of things being said about it that aren’t accurate at all, such as:

• “IR35 is being introduced in April”.  No it’s not.  IR35 has been around for more than two decades.  All that’s happening is the responsibility of non-compliance is being shifted from the contractor’s company to its customer, if the customer is big.
• “You can’t take on a contract if it’s under IR35”.  IR35 has never had anything to say about whether a contractor’s company can accept an engagement or not.  It’s legislation about how a contractor must get paid by their own company.
• Crucially – “It’s more risky to be a contractor from April”.  There might be fewer contracts around, that’s true, with more of those gigs being offered on a PAYE basis instead.  But if you’re a contractor working for a big company, and they’re content to continue paying your company’s invoices in full, there’s *less* risk than before, as the customer now bears the burden of non-compliance.  There may well be some ultra-cautious contractors who decide to declare under IR35 anyway, even if their customer is happy to pay gross, but HMRC are going to be going after the end user in the first instance, not the contractor.  Anyone in that situation will clearly be at less risk than they were before, not more.
• End users of contractors telling contractors “there are some changes coming in April, you should look into them.”  Er, no, *you* should look into them.  This is a transfer of risk *from* contractors *to* end users.  The end users are the ones who need to understand what’s happening.

What is certainly true is that some contractors are going to find themselves taking PAYE jobs instead.  And what’s also true is that many of those people will find themselves earning less money than they used to.  Some of them will be able to ask for, and get, a bigger daily rate in order to make up for it, if they have particular bargaining power for some reason, but many won’t, as their fundamental value to their client/employer hasn’t changed.

There are two ways of looking at it, really.  Some contractors will be phlegmatic about it, considering they’ve done well for a while, and that now finding themselves with a tax burden on a par with that of an employee isn’t the end of the world.  And some contractors will not be phlegmatic about it at all, especially if their life involves overheads more or less equal to their present net income.  But it is what it is, and even if the change is postponed for a second time, it will come.  The tax system isn’t fit for 2021 in many respects, and the vast number of contractors using limited companies simply wasn’t contemplated when the fundamental levers of corporation tax, income tax and National Insurance were first created. 

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Tax at Christmas (COVID edition)

Around this time of year, we usually publish a reminder about the tax rules around Christmas parties and gifts.  Of course, there's a big change this year, which is that it's rather unlikely that many employers are going to be holding Christmas parties in person.  However:

• If you decide to defer your Christmas party until some time in 2021 when (hopefully) you'll be able to hold it in a safe and legal way, you'll still be able to benefit from these allowances - an annual event is an annual event, even if it happens late.
• HMRC have confirmed that if you decide to hold some kind of event online - so, perhaps you provide everyone with their food and drink at home and all meet up on Zoom - then that event is covered by those allowances too.  To be honest, it's perfectly obvious that such an event will be covered, and we're not quite sure who would have asked for confirmation from HMRC, but there it is for avoidance of doubt!

So, having said that, the framework remains the same as ever.  If an employer provides a Christmas party that's available to all of its staff (note that this really applies to PAYE employees, as opposed to, say, freelancers), where the cost is less than £150 per head, then it can reclaim all of the VAT and deduct the entire remaining cost from its profits before working out its tax bill - effectively, if a normal VAT-registered limited company holds its party at a normal VAT-registered venue, every £100 spent on the party ends up costing the company £67 in the long run, once they've got the VAT back and saved corporation tax on what's left.  Actually, those allowances apply to annual events, not specifically Christmas ones - so you could have, say, a summer barbecue *and* a Christmas party costing less than £150 a head in total and still reclaim all of the VAT and get tax relief on the balance.

If you want to give a Christmas gift to staff, then in practice HMRC consider a relatively small item like a turkey or a fairly normal bottle of wine to be trivial, and won't try to tax the employee on the value of the gift (as we've written before, sporadic gifts and benefits each valued at £50 or less are now explicitly considered trivial by HMRC).  Assuming there's VAT on the gift when you buy it, then once more the ultimate cost of £100 of staff gifts to a normal VAT-registered limited company employer will be £67.  Anything more valuable the employees will have to pay tax on - and you'll have to pay National Insurance too.

If you give gifts to customers, then they'll only save you tax if:

• The total value of gifts in a year to the customer is less than £50,
• The gift has a clear advert for your business on it, and
• You can't eat, drink or smoke it!

If you want to give a customer a bottle of whisky then that's still completely fine, and may well make great business sense!  It's just that for every £100 you spend on gifts like that, it costs your business the full £100 - you can't reclaim any VAT or reduce your corporation tax or income tax bill at all.

www.fizzhq.com

Can I invoice my client in Euros or Dollars?

We’re often asked if it’s OK for a UK business to invoice in a currency other than GBP.  It absolutely is, but it’s sensible to consider both whether you can *and* whether you should.

The first bit is easy.  Yes, you can invoice in any currency you like!  If you’re VAT-registered, the VAT amount needs to be converted to GBP and explicitly stated on your invoice, but if it’s a B2B sale you very likely won’t have to charge VAT anyway.

The second bit – should you? – is a bit more nuanced.  Invoicing in someone else’s currency represents a transfer of risk from them to you.  If you invoice someone in France for £3,000, then exactly how many Euros that is when the payment is due is their problem, not yours.  You’re going to get £3,000 (assuming they pay you, anyway).  But if you invoice them €3,500, and they make that payment to your GBP current account, then you don’t actually know how many pounds you’re going to end up with.  It just depends upon exchange rates on the day payment is made.  Your customer now knows exactly how much they’re going to be paying out, but you’re spinning the wheel and could do well or badly depending upon exchange rate movements.

In real life, very often you won’t have a choice – it’ll depend upon where the power lies in the relationship.  If you’re working for some US tech giant, you’re going to be pitching and invoicing in USD, no doubt.  But if there’s some room for negotiation, invoicing in GBP is going to give you more certainty.  On the other hand, if you’re a risk-taker, perhaps you’ll prefer to spin the wheel and see how much you end up receiving!

If a UK business is doing lots of business in another currency, it might consider opening a bank account in that currency elsewhere.  And we discuss that here.

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Should my business open a foreign currency bank account?

Just because your business is in the UK, it doesn’t mean it can’t have bank accounts in currencies other than GBP.  It could also have bank accounts in US dollars, Euros, or any other currency for that matter.  Why might you want to do that?

We don’t invoice in currencies other than GBP.  But if we did send an invoice for €800 to a customer, and they made payment to our (GBP) bank account, the bank would convert the €800 into GBP at whatever their own exchange rate was that day.  Maybe we’d receive more pounds than €800 would have bought when we sent the invoice, maybe we’d receive less.  We’d be taking some risk though.

If we were raising lots of invoices like that, we might decide to open a Euro bank account.  That way, our customer would pay €800 and we’d receive €800.  If we then immediately transferred that into our main GBP bank account, we’d be in exactly the same position as before and it would have been a waste of time.  But there are a couple of reasons why we might not do that.

First, we might have costs in Euros as well.  If we needed to pay €700 to a subcontractor, we could do so from the Euro account.  Then we’d have only €100 left, and the consequences of getting hit by a poor exchange rate are only one eighth what they were before (of course, the possibility of cleaning up because of a good exchange rate are also lower, but we’ve got rid of the volatility).  At this level it would be silly to do that of course, but if you’ve $1m of income and $800,000 of overheads each year, limiting the exchange risk to the net $200,000 might be very smart (in an extreme case, you could get the worst of both worlds otherwise and do badly on converting both the income AND the costs from GBP, getting hit by bad exchange rates on $1.8m of transfers!).

Second, even if you’ve got no costs in that currency, you might just want the flexibility to convert to GBP when you want to, not when the payments happen.  Maybe you feel like you’ve got a good handle on how exchange rates are going to move, or maybe you’ve observed a pattern and you’re happy to transfer money into GBP whenever the exchange rate hits a certain level.

For most UK businesses, it’s probably not worth it.  But the more foreign currency that’s flowing through your business, the more it’s worth thinking about.

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The Job Support Scheme v2 – significantly more generous than v1

In an earlier blog following the announcement of the Job Support Scheme, we said that the numbers weren’t really likely to encourage a rational employer to keep staff on under the scheme. Anyway, the rules for the scheme have been torn up and replaced – it turns out the numbers weren’t really likely to encourage a rational employer to keep staff on under the scheme. Who knew!

Here’s what’s changed.

The new scheme still begins on 1 November.

Previously, it was going to require an employee to be working at least 33% of the time. The employer had to pay them for that time, of course. For the remaining non-working time, the employer would pay a third, the government would pay a third, and a third would go unpaid. The employer would pay the NI and employer pension due on the whole payment. That was pretty expensive for the employer – they were paying for a lot of idle time.

The considered, more generous scheme has two variants. One for businesses that can still legally open (JSSO) and one for ones that must close (JSSC).

JSSC is easy – if your business has been mandated to close because of government restrictions, the government will basically pay two thirds of employees' pay. The employer need pay no salary.

JSSO is more complex, naturally. Basically, the proportions have changed. The employee must now be working at least 20% of the time (so one day a week is enough, albeit someone working every - say - Wednesday might technically find themselves working less than 20% of their usual hours depending on whether there were four or five Wednesdays in that particular month, under the obtuse way that Usual Hours are framed under the JRS and JSS rules). The employer has to pay them for all their actual working time. For the remaining non-working time, whatever that may be, the employer now only has to pay 5%, the government will pay 62%, and the remaining third will still go unpaid just as before. The employer will continue to pay the NI and pension costs on the total payment, but that’s still a considerably less onerous burden for them to bear.

A bit of guidance came out last Friday, there's more due at the end of this week.  The last minute nature of it is frustrating when you might need to write to your employees to tell them what’s going to be happening to them next week.  But at least the scheme might now be useful for more employers.

www.fizzhq.com

Excel problems that aren't Excel problems

As an accountant, you do most accounting jobs using accounting software, and a few using Excel.  It's usually the smaller ones where you'd use Excel; maybe a sole trader who doesn't need to track debtors and creditors and doesn't have a dedicated business bank account, say.

Sometimes a reluctant business owner might be resistant to using accounting software, and the classic objection is "why do I have to pay for a glorified spreadsheet?".  It's not a glorified spreadsheet, that's why.  It's a database, and a database has built-in checks on the integrity of the data (in the case of accounting software, thanks to the beauty of double entry bookkeeping).

If you're not careful, then those little Excel jobs that seem the most straightforward can actually be the riskiest ones, where you can make expensive or embarrassing blunders.  When we do accounts in Excel, we always build in some kind of proof that all the transactions feeding into the accounts have been captured once, and only once, and that any adjustments are complete and transparent.  If you don't do that, all you've got is some numbers that may or may not be right.  Generally, when staff join us from another firm, they've not come across this kind of check before.  But  the extra minute or two spent proving that the output is consistent with the inputs are vital if you want the output to be reliable and credible.

Whenever we read about a big error involving the numbers in the accounts of some listed company - say an enormous error in a stock valuation - we always speculate that it will be a problem that's arisen in Excel, outside of the core accounting software.  A SUM formula that hasn't been stretched to pick up some extra rows, for example.  We're *always* right.  And often the company will try to explain it away as a problem with Excel.  It's not, of course.  It's a problem with Excel being used for an inappropriate purpose, or Excel being used for an appropriate purpose but without some kind of integrity check in place.

So, when you're using Excel for accounting, it's important to think "we need to have some sort of proof in place that the data is complete".  You also need that if you're using it to track a deadly infectious disease.

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FFS – it’s the Flexible Furlough Scheme

As of 1 July, the new version of the Coronavirus Job Retention Scheme came into play.  The good thing is that employers can now flexibly furlough their staff – it’s not all or nothing, they can work some of the time and the government will subsidise the times when there’s no work to do.  The bad thing is that it’s really complicated.

To recap two things to begin with:

1. An employee can only be part of the new JRS v2 if they completed an uninterrupted three-week period of furlough under JRS v1 by 30 June.
2. The maximum number of employees you can claim funds for in a single month under JRS v2 is the greatest number you claimed for in a single claim in JRS v1.

There’s an exception on both of those where an employee could not meet the qualification for furloughing in JRS v1 as they were on parental leave, but aside from that it’s very simple.

How does furloughing work now?

Most things are the same as they were.

For someone who is still completely furloughed, July looks identical to June in every respect – the scheme will reimburse 80% of normal pay, up to £2,500, plus associated National Insurance and statutory minimum employer pension costs.

For someone who comes back to work for good at some point in the month, July is also the same as June – the scheme will reimburse you for costs up to that point on an identical basis, and after that you’re on your own.

If someone comes back to work part-time or on some other sporadic basis, that’s flexible furlough, and that’s where it gets more complex.

If someone is flexibly furloughed, do they have to have a new formal pattern of working?

Not at all.  You just have to keep track of the hours they do work.

What can be claimed for an employee if they’re flexibly furloughed?

The employer must pay the employee’s wages in full for the time they’re working, obviously.  That’ll just be in line with their employment contract, and there’s nothing special about it.

JRS v2 will reimburse the employer for the time that the employee is not working.  It does that on the basis of “usual hours” – you have to work out the employee’s usual hours and subtract the hours they’ve worked.  The balance can be claimed under JRS v2, with the usual 80% restriction and pro-rata £2,500 cap.   As with JRS v1, you can top the employee up to 100% if you like, but it’s at your own cost.

How do I work out an employee’s usual hours?  Do I look at how many hours they’d normally have been expected to work in the month in question?

No, you don’t.

Although historically more or less all payroll calculations have always been done on the basis of actual working days, as with JRS v1 there’s a calendar day system for JRS v2.  For an employee with fixed working hours you need to assess the average hours per day in whatever the employee’s “repeating working pattern” is, then multiply that by the number of days in the month.  For an employee with variable pay, it's more complicated.

The best way to illustrate it is just with some examples.

Example 1 – an employee with fixed weekly hours

Imagine someone who works full time and does a 35-hour week, 7 hours a day Monday to Friday.  They have a repeating working pattern that’s seven days long.  That works out as five hours per day (35 divided by 7).  For July, their usual hours for flexible furlough purposes will be 155 - 5 hours multiplied by the 31 calendar days in July.   They wouldn’t really have worked 155 hours if they’d not been furloughed, because of the way the weekdays fall – there are 23 weekdays in July so they’d have worked 161 hours (7 hours multiplied by 23 working days), but that doesn’t matter.  It’s a strict calendar day calculation.

Example 2 – an employee with fixed hours who works every other Wednesday

You might, though, have an employee who does a 6-hour day on Tuesday and Thursday every week, along with every other Wednesday.  Their repeating working pattern is a fortnight, and they work 30 hours in that time.  That works out as 2.14 hours a day.  So, for July their usual hours for flexible furlough purposes would be 67 – 2.14 hours multiplied by the 31 calendar days in July, rounded up (if it’s a monthly payroll) to the nearest whole number.

By the way, as with JRS v1, you look back to the contract the employee had prior to 19 March in order to assess their contracted hours.

Example 3 – an employee with variable hours, not fixed ones

For staff on variable hours, the system for figuring out their usual hours is very similar to the one you used to work out “normal pay” under JRS v1.  You look back to 2019-20, and their usual hours for the month will be the higher of:

1. Their average hours in 2019-20 (up until the point they were furloughed, if that was prior to 5 April).
2. The hours they actually worked in the same calendar month last year.

"Average hours" here means average hours worked per day (that the employee was on the books) in 2019-20, multiplied by the number of calendar days in the month you're working out their pay for now.  So, if someone was on your payroll all through 2019-20, wasn’t furloughed until after 5 April, and worked 684 hours in the year, that’s 1.87 hours a day.  Usual hours for July 2020’s 31 days would therefore be 58.  But if they did more than 58 hours in July 2019, you’d use that bigger total instead as their usual hours for July 2020.

The calculations become more complex still if the pay period is not a calendar month.  We’re very happy that nearly all the payrolls we run are for the calendar month!

How much must I pay the employee for the flexibly furloughed hours?

Again, you need to go back and look at last year’s pay.

If our employee from example 3 did fewer than 58 hours in July 2019 and therefore those hours don’t take precedence, their usual hours for the July 2020 calculations are 58.  If they actually worked 31 hours, you’ll just pay for those as normal.  For the other 27, you look back to 2019-20, and find the higher of:

1. Their average monthly pay in 2019-20, or
2. Their pay in the same calendar month last year.

Whichever is the higher, you take 27/58ths of it, and 80% of that is the amount that they must be paid, and that HMRC will reimburse.  As ever, you can top up with the extra 20%, but at your own cost etc.

As with JRS v1, it doesn’t matter if that’s less than National Minimum Wage.

How are the claim amounts going to change over time?

At present, if you’re paying the furloughed employee 80% of normal pay, then the government is covering the lot.  Your employee is still accruing holiday entitlement, but that’s the only real cost to you.  However, the support is being tapered away.  Here’s what can be claimed:

July is just the same as June:  80% of salary (up to a monthly equivalent of £2,500) for the time on furlough, plus Employer’s National Insurance and minimum statutory pension contributions for that time.

August: Just the 80% of salary (capped at £2,500).  You’re on your own with the pension and NI.

September: Just 70% of that salary.  You still have to pay at least 80%, so the extra 10% is now out of your pocket, along with the pension and NI.

October: Just 60% of that salary.  You still have to pay at least 80%, so the extra 20% is now out of your pocket, along with the pension and NI.

At least that means that the claims get somewhat simpler from August onwards, since two of the three components drop out!  Perhaps we should be grateful for small mercies. 

www.fizzhq.com

"Should I put this new sideline through my limited company?"

Pretty often, someone tells us about a new activity that they've started engaging in to make a bit of money on the side. They wonder whether they should channel the income through the limited company they make their main living from, or if they should keep it separate.

In most cases, there are three big picture factors to think about.

First, there's a fundamental elegance to having all of your income going through the same vehicle. One of the benefits of a limited company is that you can chuck all sorts in revenue in, and draw your income out in a steady manner - that way, you can plan your income and tax bills, smooth out variable business profits over the years, and perhaps build up a safety cushion for the future. If you have multiple personal sources of income, things are a bit trickier. So the default is to stick everything through the company, and it's virtually always possible to do that.

However, then you have to think about VAT. If your company is VAT registered, its new sideline is going to be VATable too. That's fine if it's a business-to-business sideline - most likely the customers won't care if you add VAT to your prices. If it's business-to-consumer, though, the customers will care - the VAT is a real cost to them. So you're going to have to suck it up and pay the VAT out of the selling price, meaning 1/6th of the income going straight to HMRC before even thinking about corporation tax. So, for a B2C sideline, you might decide to operate as a sole trader. If you want to do that, though, the businesses really need to be kept separate (i.e. separate customer invoices, getting paid into a different bank account, keeping separate records, placing separate orders for any materials etc), to reduce the risk of HMRC successfully arguing that it's really just one big VATable business.

Finally, there's the trading allowance. For the last few years, sole traders have been able to claim a flat deduction of £1,000 in place of actual costs in order to work out their taxable profits. Your limited company won't get that deduction, it must claim actual costs, and maybe there aren't many of those. So you might want to keep the sideline as sole trader income; if it's under £1,000 you don't have to report it to HMRC at all.

Obviously, there are other factors too - and if it's not a sideline but a real business you'd certainly consider it in more detail. But for anyone trying at present to boost their income just a little bit, those are the first three things we'd think about. And that's a conversation best had before the sideline kicks off - if you've already agreed a contract or sale with a customer as a limited company, you can't just change your mind later!

www.fizzhq.com

Can I charge interest if my invoice is paid late?

For a long time now, businesses have had the legal right to charge interest (and, in fact, compensation and costs) when invoices are paid late, at 8% above the Bank of England base rate.  In real life, you very rarely see the right exercised, maybe because people don't know they can do it, maybe because for small invoices paid a bit late it's not that much money, but probably mostly because the supplier doesn't want to antagonise a client and colour the relationship. 

But actually businesses that pay invoices late sometimes don't seem too upset when they're legitimately charged interest - they see paying invoices late as a perfectly normal part of business, and the interest as a perfectly normal consequence.  We remember one or two clients who've been very reluctant to charge interest to recalcitrant customers, who eventually found that the customers were quite content to pay.

There's a useful calculator you can use here to work out how much interest you could charge on an invoice that's been paid late, with some helpful wording for the invoice:

https://www.smallbusinesscommissioner.gov.uk/deal-with-an-unpaid-invoice/how-to-chase-an-unpaid-invoice/interest-calculator/

Obviously, maybe you've got a customer who really will be aggravated if you charge interest, and it won't be worth it.  But small businesses should probably exercise the right to do it more often than they do.

www.fizzhq.com

Can directors furlough themselves?

A couple of weeks ago the government announced that they would subsidise employees' wages if, rather than laying them off in the crisis, employers kept them on anyway.  If they do that, and the employer expects the government subsidy, the employee is to all intents and purposes not allowed to work at all.  That process is known as "furloughing".  It's been a big deal.  Between 2007 and the Friday before last, the word "furlough" came up in precisely two of Greg's emails in 13 years.  Since the Friday before last, it appears in 189 separate conversations.

The scheme is aimed at employees, not business owners.  But some directors of limited companies have found that their work has completely dried up, and so understandably have asked if they can furlough themselves so that their company gets some contribution towards their own (usually around £700) salary.

The idea of a company director furloughing themselves is basically a logical nonsense.  Even if absolutely every bit of fee-earning work has dried up, and there's no point looking for more, a company director still has legal obligations around the stewardship of the company - there's an obvious Catch 22, where as soon as a director suggests to us that they've furloughed themselves, the fact that they're talking to us means they're still engaged in company business!  And even if fee-earning work has disappeared, many directors will be working hard to try and find new revenue for the company to fill the gap.

However - it's now clear HMRC are in practice going to be content with claims from companies against part of a director's small salary where the company's income-generating work has totally dried up.  They probably realise that limited company owners - especially ones with company income under £50,000 who would have been given some support had they been a sole trader - have fallen through a crack in the system, and they're saying they'll accept claims from companies relating to small director salaries if absolutely all fee-earning work has disappeared.  On that basis, the subsidy the company could expect for a month of inactivity would be about £575, at present for up to three months (assuming a total absence of fee-earning work over a three month period).

Anyway, there's no action to take now.  The claims process for getting the subsidy for furloughed workers doesn't exist yet, and HMRC are hoping to have it in late April.  So for now, directors with no fee-earning work to do will have to be patient - and in the meantime try and find some other source of company income, which hopefully will be greater than that relatively small subsidy.  Of course, as soon as the reclaim portal exists we'll be letting clients know!

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