• Enhancements to CEST are being suggested and should be available before the reform comes in to effect – though we all know this didn’t happen previously.

• Any changes in the new legislation is likely to impact the public sector as well, so Public Sector will face a revisit too.

• HMRC are aware of the lack of legislative requirement to pass the determination and its reasons down the contractual chain and the absence of a legal process to deal with status disagreements so they intend to introduce a framework for resolving disagreements.

• If any party in the contractual chain fails to fulfill its obligations then the tax will be payable by them.

• HMRC intends to go up the supply chain if taxes are not paid over and the party responsible ceases to exist – really risky for agencies if they choose dodgy suppliers. They say this will ensure compliant behaviour in the supply chain and propose that everyone should choose to work with reputable and compliant firms

• HMRC claims 85% correct rate for CEST, but acknowledge that it does not take existing case law into consideration, but did not mention MOO (Mutuality of Obligation)

• HMRC urge organisations to prepare for the reforms in plenty of time.

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