Brief

On 16/01/2025, Her Majesty’s Revenue and Customs (HMRC) issued an update regarding HMRC's approach to labour supply chain risks. This approach focuses on tackling tax risks and illegal working practices in labour supply chains across all business sectors. By strengthening legislation, investigating and enforcing non-compliance, and raising awareness among businesses, HMRC aims to prevent the exploitation of people and create a level playing field for compliant businesses.

HMRC's approach to labour supply chain risks

Explains the ways that HMRC works to tackle tax risks and illegal working practices in labour supply chains.

HMRC is committed to tackling tax risks and illegal working practices in labour supply chains, across all business sectors. The work that we do helps to:

fund essential UK services
stop the exploitation of people
create a level playing field for compliant businesses

Strengthening legislation and processes

We continually work to inform legislation and strengthen our own processes to enable us to address non-compliance within LSCs. Examples include the:

introduction of the VAT domestic reverse charge
reform of the off-payroll working (IR35) rules
announcement of legislation to tackle non-compliance in the umbrella company market
introduction of the publication of promotors of known avoidance schemes

Investigating and enforcing

The activity that HMRC undertakes to identify and address non-compliance includes:

working with partners such as the National Crime Agency, police and the Gangmasters Labour Abuse Authority (GLAA) to investigate issues and enforce laws
undertaking supply chain investigation and monitoring
using legislative powers and those established through caselaw to address tax risks to prevent and recover tax losses
prosecuting those committing and facilitating tax evasion

Raising awareness

As well as responding to non-compliance, HMRC also works to promote the importance of reducing the likelihood of LSC risks in the longer term. Ongoing activity includes improving understanding of LSC risks and the importance of effective supply chain assurance by:

publishing guidance on the GOV.UK website
sharing information on supply chain risks to raise awareness and inform businesses for example, where HMRC sees particular trends or increases in risk
engaging with businesses who want to reduce risks in their supply chain
working with other government departments, organisations and businesses to improve the health of labour supply chains, economically, environmentally and socially

Highlights content goes here...

Purpose
HMRC’s approach to labour supply chain risks is to tackle tax risks and illegal working practices in labour supply chains, across all business sectors. The objective is to fund essential UK services, stop the exploitation of people, and create a level playing field for compliant businesses.

HMRC aims to achieve this by continually working to inform legislation and strengthen its own processes to enable it to address non-compliance within Labour Supply Chains (LSCs). This includes introducing new regulations, reforming existing rules, and announcing legislation to tackle specific non-compliance issues in the labour supply chain market. HMRC also publishes guidance on GOV.UK websites to improve understanding of LSC risks and the importance of effective supply chain assurance.

HMRC’s approach is proactive, working with partners such as the National Crime Agency, police, and the Gangmasters Labour Abuse Authority (GLAA) to investigate issues and enforce laws. It undertakes supply chain investigation and monitoring, using legislative powers and those established through caselaw to address tax risks and prevent and recover tax losses. HMRC also prosecutes those committing and facilitating tax evasion.

Effects on Industry
The effects of HMRC’s approach on the industry are multifaceted. Firstly, it creates a level playing field for compliant businesses by tackling non-compliance within Labour Supply Chains (LSCs). This ensures that all businesses, whether they use LSCs or not, are subject to the same tax rules and regulations.

Secondly, HMRC’s approach helps fund essential UK services by preventing tax losses. By recovering taxes owed to it, HMRC can invest in vital public services such as healthcare, education, and infrastructure.

Lastly, HMRC’s approach raises awareness about LSC risks and promotes effective supply chain assurance among businesses. This encourages companies to take steps to reduce the likelihood of LSC risks in their supply chains, creating a safer and more transparent business environment.

Relevant Stakeholders
The relevant stakeholders affected by HMRC’s approach are:

  • Businesses that use Labour Supply Chains (LSCs) to source labour
  • Compliance officers responsible for ensuring tax compliance within businesses
  • Suppliers and contractors who may be involved in LSCs
  • Trade unions and worker representatives concerned with fair working practices and minimum wage adherence

Next Steps
To comply with HMRC’s approach, businesses must:

  • Ensure they have effective supply chain assurance processes in place to prevent non-compliance within Labour Supply Chains (LSCs)
  • Review their tax compliance procedures to ensure alignment with HMRC’s rules and regulations
  • Engage with HMRC through the GOV.UK website or by contacting a local tax office for guidance on specific issues

Businesses must also be aware of new legislation and processes introduced by HMRC, such as changes to VAT and off-payroll working (IR35) rules. They should stay informed about trends and increases in LSC risks to adapt their business practices accordingly.

Any Other Relevant Information
Additional relevant information includes:

  • The introduction of the VAT domestic reverse charge and reform of IR35 rules demonstrate HMRC’s commitment to tackling non-compliance within Labour Supply Chains (LSCs)
  • HMRC works with other government departments, organisations, and businesses to improve the health of labour supply chains economically, environmentally, and socially
  • HMRC publishes guidance on GOV.UK websites to raise awareness about LSC risks and promote effective supply chain assurance among businesses

Her Majesty’s Revenue and Customs (HMRC)

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