Lessons from implementing IR35 reforms

This is a House of Commons Committee report, with recommendations to government. The Government has two months to respond.

Second Report of Session 2022–23

Author: Committee of Public Accounts

Related inquiry: Lessons from implementing IR35 reforms

Date Published: 25 May 2022

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Contents

Introduction

The government originally introduced the IR35 off-payroll working rules in April 2000, with the objective to prevent tax avoidance by ‘disguised employees’. These are people who do the same job in the same manner as an employee but avoid income tax and National Insurance contributions (NICs) by providing services through an intermediary such as a personal service company (PSC). The legislation therefore introduced a requirement for workers engaged through intermediaries to assess their employment status for tax purposes. If they are deemed to be a ‘disguised employee’ they will be subject to income tax and NICs at source in the same way as regular employees.

However, HMRC found that adherence to these rules was low despite government efforts to improve compliance between 2007 and 2015. In 2016, HMRC estimated that only 10% of PSCs were applying the IR35 rules correctly, costing the exchequer £440 million in the 2016–17 financial year. To improve compliance, the government introduced reforms that shifted responsibility for making status determinations from the worker to the hiring body, which also became liable for any unpaid tax where it had failed to comply. These reforms initially applied to the public sector from April 2017 (affecting around 50,000 PSCs) and were extended to include the private and third sectors in April 2021 (affecting an estimated 180,000 further PSCs).

Conclusions and recommendations

1. High levels of non-compliance in central government reflect poor implementation by HMRC and other government bodies. Central government is spending hundreds of millions of pounds to cover tax owed for individuals wrongly assessed as self-employed. Government departments and agencies owed, or expected to owe, HMRC £263 million in 2020–21 due to incorrect administration of the rules. This is not acceptable considering government departments should be in a good place to understand the rules and communicate with HMRC. However, mistakes were likely as the reforms were rushed in by HMRC and public bodies were given little time to prepare—in particular, they had only two months or less with HMRC’s new guidance and tools before the new rules came into effect. There were also problems with the guidance and Check Employment Status for Tax (CEST) tool that HMRC provided. Some questions within CEST were difficult to interpret correctly, and the guidance was long, too general in scope and not integrated into CEST itself. Employment status is a challenging area to get right, and we are concerned that non-compliance in the public sector may be much more widespread than the instances HMRC has identified so far.

Recommendation: HMRC should develop robust estimates of non-compliance for the public sector as a whole and use this to identify areas where it can reduce the inherent challenge of complying with the reforms, for example by improving its guidance and tools. It should adopt a similar approach for the private sector as the reforms bed in and write to us with an update in six months’ time.

2. We are concerned that it is too difficult for workers to challenge incorrect status determinations. The absence of a clear definition of self-employment, and limited access to relevant personal information for each contractor, can make it challenging for hiring organisations to make status determinations confidently. Hiring organisations can face significant financial consequences if they incorrectly assess someone as self-employed, and this risk may affect their determinations. Workers can challenge decisions with the hiring organisation, but they have no independent route to appeal. The hirer must respond formally to an appeal from a contractor within 45 days. However, if they do not change the status, the worker has no further recourse other than to seek a refund from HMRC by completing their self-assessment return on a self-employed basis. It is unclear how effectively these routes operate in practice and the extent to which they are used, because HMRC does not monitor this.

Recommendation: HMRC should ensure there is a fast and independent process for contractors to resolve disputes over status determinations. As part of this, it should assess the extent to which workers are using existing appeals routes, and how well they are working.

3. HMRC is not doing enough to understand the impact of the reforms on workers and labour markets. The complexity of the rules, and the perceived risk to hiring organisations of failing to comply with them, may lead to changes in behaviour by both workers and hirers. In some cases, contractors have reported that their last clients had stopped all use of PSCs, while some contractors have increased their rates or avoided work if it is within scope of the IR35 rules. Such behavioural impacts could have knock-on consequences for workers and labour markets, such as loss of work or ability to work flexibly. HMRC has not carried out research into these types of wider impacts, and it is not convinced by evidence provided by others even where this indicates there may be significant issues. HMRC is also too dismissive where a significant minority of people and businesses report being adversely affected.

Recommendation: HMRC should conduct and publish specific research into the impacts of the IR35 reforms on contractors and labour markets, to check it is being applied as intended and not adversely affecting employment opportunities.

4. We are not confident that HMRC works proactively to establish whether any sectors have been affected disproportionately by the reforms and why. Issues in UK supply chains have been widely reported in recent months, for example in fuel and groceries. It is unclear to what extent the IR35 changes may have contributed to these by affecting hiring practices or decisions by contractors in key parts of the workforce. Particular concerns around difficulties in implementing the rules have also been raised by contractors in the broadcasting and IT sectors, and these issues may be compounded in areas that have seen changes to more flexible and ad-hoc working practices in recent years. We do not have confidence that HMRC is identifying which sectors may be disproportionately affected, nor that it is working proactively with affected sectors to understand what issues they are facing and how these might be addressed.

Recommendation: HMRC should proactively identify and work with sectors that have been particularly affected to understand the challenges, establish how to address them and make it easier to comply. HMRC should write to us with an update in six months with the outcome of this public engagement.

5. HMRC has not made a robust assessment of the additional costs of implementing the reforms. HMRC states that the IR35 reforms increased tax revenues by increasing the number of people employed for tax purposes, but it is unclear to what extent employment patterns have been affected by other factors. EU Exit, the COVID-19 pandemic and other changes in government to reduce use of contractors mean HMRC cannot be certain to what extent the increase is due to the reforms. There is also not a complete picture of the costs of the reforms against which the benefits could be compared. The government introduced the reforms because it considered it too costly for HMRC to oversee an effective compliance regime with each individual PSC. HMRC also concluded that hiring organisations could administer the rules for less cost than PSCs doing it themselves. However, HMRC’s modelling of the cost to hiring organisations works out at just £35 a year per PSC, based on a theoretical minimum needed to comply. HMRC does not know what it actually costs all parts of the labour supply chain to administer the reforms in practice.

Recommendation: In light of actual experience, HMRC should produce and present to Parliament a cost-benefit analysis of the reforms that reflects the actual costs of compliance to HMRC itself, hiring organisations, workers, and others in the supply chain.

6. Despite years of reforming the IR35 rules, there are still structural problems with how they work in practice. The IR35 rules do not work well with the realities of contracting, both in determining workers’ tax status and in resolving issues when mistakes have been made. For example, hiring organisations are now responsible for assessing tax status, but may not have access to all the information necessary to assess the totality of a worker’s income and other work. While HMRC interprets IR35 as applying to individual engagements, recent court cases have focused more on a worker’s business in the round. The legal framework and realities of contracting also make it difficult to correct errors if HMRC later finds a hiring organisation to be non-compliant. Hirers often lack the data on affected workers that HMRC would need to work out their actual tax position. Furthermore, the legislative framework does not allow HMRC to offset liabilities against taxes already paid, meaning it collects tax twice on the same income and workers become able to reclaim all the tax they paid. Ironically, the public sector may end up paying all the tax on workers it incorrectly assessed as self-employed. This position does not look sustainable and risks being more costly to all parties the longer it goes on.

Recommendation: HMRC should review how the system is working and whether it can be made more efficient and effective. In particular, it should develop solutions to address problems with how the IR35 rules work in practice, including ensuring that:

  • HMRC has the data it needs to accurately reflect each worker’s tax position in cases of non-compliance; and
  • HMRC does not end up taxing the same income twice, or unwittingly contributing to workers not paying their fair share in tax.

1 How the IR35 reforms work in practice

1. On the basis of a report by the Comptroller and Auditor General, we took evidence from HM Revenue & Customs (HMRC) regarding the implementation of off-payroll working tax rules, known as IR35.1

2. The government originally introduced the IR35 off-payroll working rules in April 2000, with the objective to prevent tax avoidance by ‘disguised employees’. These are people who do the same job in the same manner as an employee but avoid income tax and National Insurance contributions (NICs) by providing services through an intermediary such as a personal service company (PSC). The government introduced the rules in response to concerns that many contractors were using these arrangements—often encouraged by their clients—purely for the purpose of avoiding tax, due to higher tax rates for employees than for companies or the self-employed. The 2000 legislation therefore introduced a requirement for workers engaged through intermediaries to assess their employment status for tax purposes. If they are deemed to be a ‘disguised employee’ they will be subject to income tax and NICs at source in the same way as regular employees.2

3. However, HMRC found that adherence to these rules was low despite government efforts to improve compliance between 2007 and 2015. In 2016, HMRC estimated that only 10% of PSCs were applying the IR35 rules correctly, costing the exchequer £440 million in the 2016–17 financial year. HMRC identified that needing to examine each PSC for each engagement meant it could never successfully assure overall compliance, meaning limited incentives for contractors and their PSCs to comply.3

4. To improve compliance, the government introduced reforms that shifted responsibility for making status determinations from the worker to the hiring body, which also became liable for any unpaid tax where it had failed to comply. These reforms initially applied to hiring organisations in the public sector from April 2017, which HMRC estimates affected around 50,000 PSCs. The government later extended the reforms to the private and third sectors in April 2021, affecting an estimated 180,000 further PSCs.4

Compliance by public bodies

5. Government departments and agencies owed or expected to owe a total of £263 million in back-taxes to HMRC in 2020–21 because HMRC found that they had not administered the reforms correctly.5 Government departments should have been in a good place to understand the rules and communicate with HMRC, but HMRC told us they struggled more than other public sector organisations as key personnel did not understand the contractual framework underlying how they hired contractors. For example, they were incorrectly judging that contractors could always provide a substitute to do their work, which was not the case.6

6. HMRC told us it provided a wide range of support to public bodies before and after implementation of the reforms, beginning in 2015 and intensifying in 2016 and 2017, to help ensure the public sector was ready.7 However, it made new guidance and tools, aimed at helping public bodies implement the new rules in practice, available only two months or less before the reforms took effect.8 There were also problems with the guidance and Check Employment Status for Tax (CEST) tool that HMRC provided. Some questions within CEST were difficult to interpret correctly, and the guidance was long, too general in scope and not integrated into CEST itself.9 HMRC told us the limited time available to public bodies was the result of a ministerial decision to protect the Exchequer, and that giving public bodies more time to comply may have meant the systemic problems with compliance took longer to find.10

7. We asked HMRC what level of non-compliance it expected there to be in smaller public bodies, and whether well-resourced departments struggling to comply is a worrying sign for the reforms more generally. HMRC suggested that smaller organisations may be better placed to comply, if key personnel involved in compliance are closer to the hiring parts of the organisation.11 However, HMRC also acknowledged that its compliance efforts had mainly been focused on government departments so far, after identifying a higher chance of compliance problems in its early risk assessments, compared with other public bodies.12

The ability of workers to appeal incorrect status determinations

8. The absence of a clear definition of self-employment, and limited access to relevant personal information for each contractor, can make it challenging for hiring organisations to make status determinations confidently.13 Hiring organisations can face significant financial consequences if they incorrectly assess someone as self-employed, and this risk may affect their determinations.14

9. Since 2021, individuals have had the statutory right to raise a dispute with their hirer if they disagree with their status determination, and the hiring organisation must respond formally within 45 days. If both parties continue to disagree, the worker does not have an independent route for further appeal, but can seek a refund from HMRC by completing their self-assessment return with what they believe to be the correct tax treatment. There is no route for individuals to appeal past this point.15

10. We asked HMRC to what extent it considered that hiring organisations were treating workers unfairly, for example by using ‘blanket assessments’ instead of assessing workers on a case-by-case basis. HMRC told us it had seen limited evidence of blanket assessments, and that around 500 workers had contacted them because they believe they have not been treated correctly.16 HMRC considers these reports when assessing risk of error and non-compliance by hiring organisation, and told us it would be unable to tell us the outcome of these cases until it has completed its follow-up work.17 HMRC also explained that an individual raising concerns may have to wait months or years for a resolution depending on the complexity of the case and the cooperation of the parties involved.18

Structural problems with the way the rules work

11. Evidence received from stakeholders indicated that many of the challenges with IR35 stem from underlying issues in tax administration.19 HMRC told us that it would be simpler and more straightforward to administer the tax system if tax liabilities of employed and self-employed were aligned, but that this is ultimately a matter for Ministers and Parliament.20 Nevertheless, we examined whether there are structural problems with how the rules work in practice.

12. The IR35 reforms made hiring organisations responsible for determining a contractor’s tax status.21 HMRC told us it interprets IR35 as applying to individual engagements, but that courts have not always taken the same approach. In particular, recent court rulings suggest that it may be necessary to consider a contractors’ work portfolio and income in the round, rather than on an engagement-by-engagement basis. If so, it is hard to see how a hiring organisation can realistically have all the information it would need to do this better than the workers themselves.22

13. The realities of contracting also mean that hiring organisations will likely not have the data required to identify and correct mistakes when workers have been incorrectly engaged on a self-employed basis. In particular, the hirer would not normally collect a worker’s National Insurance number if they are self-employed. However, if HMRC later judges that the worker should have been treated as employed, it needs the National Insurance number to identify their actual tax position. This means that when HMRC finds workers have been misclassified, it normally lacks the data to accurately calculate the additional taxes owed.23

14. Furthermore, the current legal framework does not let HMRC offset liabilities for non-compliance against any taxes already paid by workers and their PSCs.24 In law, HMRC must collect the full taxes that should originally have been paid from the hiring organisation. This means that HMRC collects tax twice on the same income, and that workers become able to reclaim all the taxes they already paid without needing to compensate the hiring organisation.25 Ironically, the public sector may therefore end up paying all the tax on workers it incorrectly assessed as self-employed. HMRC does not know how much this is happening, or to what extent it means the public sector is effectively subsidising private contractors.26 One tax advice firm told us that this issue has been raised with HMRC for some time, but HMRC has no current plans to address it.27

2 Understanding the impacts of the IR35 reforms

The impact of the reforms on workers and labour markets

15. The complexity of the rules, and the perceived risk to hiring organisations of failing to comply with them, could lead to changes in behaviour by both workers and hirers. For example, while firms must assess each role individually and not make blanket assessments, they are perfectly within their rights to mitigate risks by reducing their use of off-payroll workers in the first place.28 These forms of behavioural impacts could have knock-on consequences for workers and labour markets, such as loss of work or ability to work flexibly.29

16. Stakeholders have for some time reported that risk-averseness of hiring organisations could result in a decision to stop engaging freelance contractors.30 More recently, surveys conducted by organisations that represent or provide tax advice to contractors have found substantial numbers of contractors reporting that their last clients either completely ceased using PSCs or made a blanket determination that all off-payroll workers should be employed for tax purposes.31 HMRCs own research into the experience of public bodies has also found that significant minorities of hiring organisations had experienced difficulties filling vacancies, or had seen contractors increasing their fee rates.32

17. HMRC has not carried out research into these types of wider impacts from the perspective of workers, and is not convinced by evidence provided by others even where this indicates there may be significant issues.33 In its own research, HMRC has also presented the reforms as a success despite consistently finding that significant minorities of people and businesses have been adversely affected. For example, in HMRC’s latest research into the impacts of the reforms impacts on public bodies, 19% of ‘sites’ (a single location of an organisation that administers its own payroll) and 34% of ‘central bodies’ (bodies providing payroll services for multiple locations or organisations) reported that they had found it more difficult to fill contractor vacancies since April 2017.34 When reporting its findings, HMRC focuses on the experience of the majority rather than the problems faced by the large minority.35

Understanding which sectors have been particularly affected

18. In addition to understanding the impact of the reforms on the economy and workforce as a whole, it is also important to establish whether any sectors have been disproportionately affected and what additional guidance or support may be needed. For example, issues in UK supply chains have been widely reported in recent months, such as in fuel and groceries. There are particular concerns among IT contractors that they are missing out on contracts as a result of engagers wanting to avoid the process of assessing them for their IR35 status, and in some cases hiring overseas where the rules do not apply.36 There have also been concerns raised in the broadcasting sector, and we reported in April 2019 on problems the BBC faced implementing the reforms.37

19. It is not yet clear to what extent the IR35 changes may have contributed to these issues by affecting hiring practices and decisions made by contractors in key parts of the workforce.38 HMRC believes that the reforms are unlikely to have had a material impact on the flexibility of the labour market but acknowledges that it does not yet have evidence on this, and its research has not examined whether there are particular issues in particular sectors.39 Stakeholders have reported that HMRC could do more to work with different sectors to understand the challenges they face, help develop more specific guidance and ensure that its CEST tool works equally well regardless of sector and role.40 HMRC told us of the ways it engages with stakeholders to monitor developments, particularly through its IR35 Forum. But there remain questions for how well HMRC can keep up with rapidly emerging and changing sectors, particularly in areas that have seen changes to more flexible and ad-hoc working practices in recent years.41

Assessing total costs and benefits of the reforms

20. HMRC states that the IR35 reforms increased tax revenues by increasing the numbers of workers deemed to be employed for tax purpose. It has estimated that there was a net increase in tax revenue of £250 million during the first year of the reform, and an additional 50,000 individuals put on payroll during the first two years.42 HMRC told us that the estimated increase in yield was £275 million in the second year.43 HMRC told us it is confident that it can attribute the increase to the reforms in the short term.44 However, it is difficult to disentangle the impacts of the reform from other factors that may have affected employment patterns. EU Exit, the COVID-19 pandemic and wider changes in government resourcing to reduce use of contractors mean HMRC cannot be certain to what extent the increase is due to the reforms.45

21. There is also not a complete picture of the costs of the reforms against which the benefits could be compared. HMRC has estimated the cost to hiring organisations, but its modelling is based on a theoretical minimum needed to comply, rather than an estimate of what it actually costs organisations to administer the reforms in practice. While HMRC revisited its cost estimates in light of challenge and recommendations it received from a House of Lords inquiry in 2020, its basic approach has not changed. This means it is still based on a theoretical minimum, and still only covers the private sector.46 HMRC estimated that ongoing costs for the private sector would be £8.4 million a year, and that 240,000 PSCs would need to have their tax status assessed.47 This means an average cost to hiring organisations—to determine the tax status and perform all other administrative activities—of £35 a year per PSC. HMRC’s research has asked surveyed public bodies what they are spending in practice, but it does not have a total estimate for the public sector to compare with its previous estimates.48

22. HMRC does not have estimates for the costs incurred by organisations other than hiring bodies. The government introduced the reforms because it considered it too costly for HMRC to oversee an effective compliance regime with each individual PSC.49 It is not clear what HMRC’s own costs are for its compliance work before and after the reforms.50 In estimating the administrative burdens of the reforms to the private sector, HMRC also assumed that hiring organisations can administer the rules for less cost than PSCs doing it themselves.51 However, HMRC acknowledges that this assumption was based on PSCs applying the rules correctly under the previous regime, which is not what was happening in the real world—indeed, in 2016, HMRC estimated that only 10% of PSCs were compliant.52 It is also not evident that PSCs will no longer incur any administrative costs, particularly where only part of their business is determined as within the IR35 rules, which creates additional complexity and therefore cost.53

Formal minutes

Wednesday 11 May 2022

Members present:

Dame Meg Hillier

Shaun Bailey

Sir Geoffrey Clifton-Brown

Peter Grant

Kate Green

Antony Higginbotham

Angela Richardson

James Wild

Lessons from implementing IR35 reforms

Draft Report (Lessons from implementing IR35 reforms), proposed by the Chair, brought up and read.

Ordered, That the draft Report be read a second time, paragraph by paragraph.

Paragraphs 1 to 22 read and agreed to.

Summary agreed to.

Introduction agreed to.

Conclusions and recommendations agreed to.

Resolved, That the Report be the Second of the Committee to the House.

Ordered, That the Chair make the Report to the House.

Ordered, That embargoed copies of the Report be made available, in accordance with the provisions of Standing Order No. 134.

Adjournment

Adjourned till Monday 16 May at 3:30pm


Witnesses

The following witnesses gave evidence. Transcripts can be viewed on the inquiry publications page of the Committee’s website.

Monday 21 February 2022

Jim Harra, Chief Executive and First Permanent Secretary, HM Revenue and Customs; Nicole Newbury, Director for Wealthy and Mid-Sized Business Compliance, HM Revenue and Customs; Pete Downing, Deputy Director Employment Status and Intermediaries, HM Revenue and CustomsQ1–88


Published written evidence

The following written evidence was received and can be viewed on the inquiry publications page of the Committee’s website.

NAO numbers are generated by the evidence processing system and so may not be complete.

1 Chaplin, Mr Dave (NAO0002)

2 Institute of Chartered Accountants in England and Wales (ICAEW) (NAO0001)


List of Reports from the Committee during the current Parliament

All publications from the Committee are available on the publications page of the Committee’s website.

Session 2022–23

Number

Title

Reference

1st

Department for Business, Energy & Industrial Strategy Annual Report and Accounts 2020–21

HC 59

3rd

The future of the Advanced Gas-cooled Reactors

HC 118

Session 2021–22

Number

Title

Reference

1st

Low emission cars

HC 186

2nd

BBC strategic financial management

HC 187

3rd

COVID-19: Support for children’s education

HC 240

4th

COVID-19: Local government finance

HC 239

5th

COVID-19: Government Support for Charities

HC 250

6th

Public Sector Pensions

HC 289

7th

Adult Social Care Markets

HC 252

8th

COVID 19: Culture Recovery Fund

HC 340

9th

Fraud and Error

HC 253

10th

Overview of the English rail system

HC 170

11th

Local auditor reporting on local government in England

HC 171

12th

COVID 19: Cost Tracker Update

HC 173

13th

Initial lessons from the government’s response to the COVID-19 pandemic

HC 175

14th

Windrush Compensation Scheme

HC 174

15th

DWP Employment support

HC 177

16th

Principles of effective regulation

HC 176

17th

High Speed 2: Progress at Summer 2021

HC 329

18th

Government’s delivery through arm’s-length bodies

HC 181

19th

Protecting consumers from unsafe products

HC 180

20th

Optimising the defence estate

HC 179

21st

School Funding

HC 183

22nd

Improving the performance of major defence equipment contracts

HC 185

23rd

Test and Trace update

HC 182

24th

Crossrail: A progress update

HC 184

25th

The Department for Work and Pensions’ Accounts 2020–21 – Fraud and error in the benefits system

HC 633

26th

Lessons from Greensill Capital: accreditation to business support schemes

HC 169

27th

Green Homes Grant Voucher Scheme

HC 635

28th

Efficiency in government

HC 636

29th

The National Law Enforcement Data Programme

HC 638

30th

Challenges in implementing digital change

HC 637

31st

Environmental Land Management Scheme

HC 639

32nd

Delivering gigabitcapable broadband

HC 743

33rd

Underpayments of the State Pension

HC 654

34th

Local Government Finance System: Overview and Challenges

HC 646

35th

The pharmacy early payment and salary advance schemes in the NHS

HC 745

36th

EU Exit: UK Border post transition

HC 746

37th

HMRC Performance in 2020–21

HC 641

38th

COVID-19 cost tracker update

HC 640

39th

DWP Employment Support: Kickstart Scheme

HC 655

40th

Excess votes 2020–21: Serious Fraud Office

HC 1099

41st

Achieving Net Zero: Follow up

HC 642

42nd

Financial sustainability of schools in England

HC 650

43rd

Reducing the backlog in criminal courts

HC 643

44th

NHS backlogs and waiting times in England

HC 747

45th

Progress with trade negotiations

HC 993

46th

Government preparedness for the COVID-19 pandemic: lessons for government on risk

HC 952

47th

Academies Sector Annual Report and Accounts 2019/20

HC 994

48th

HMRC’s management of tax debt

HC 953

49th

Regulation of private renting

HC 996

50th

Bounce Back Loans Scheme: Follow-up

HC 951

51st

Improving outcomes for women in the criminal justice system

HC 997

52nd

Ministry of Defence Equipment Plan 2021–31

HC 1164

1st Special Report

Fifth Annual Report of the Chair of the Committee of Public Accounts

HC 222

Session 2019–21

Number

Title

Reference

1st

Support for children with special educational needs and disabilities

HC 85

2nd

Defence Nuclear Infrastructure

HC 86

3rd

High Speed 2: Spring 2020 Update

HC 84

4th

EU Exit: Get ready for Brexit Campaign

HC 131

5th

University technical colleges

HC 87

6th

Excess votes 2018–19

HC 243

7th

Gambling regulation: problem gambling and protecting vulnerable people

HC 134

8th

NHS capital expenditure and financial management

HC 344

9th

Water supply and demand management

HC 378

10th

Defence capability and the Equipment Plan

HC 247

11th

Local authority investment in commercial property

HC 312

12th

Management of tax reliefs

HC 379

13th

Whole of Government Response to COVID-19

HC 404

14th

Readying the NHS and social care for the COVID-19 peak

HC 405

15th

Improving the prison estate

HC 244

16th

Progress in remediating dangerous cladding

HC 406

17th

Immigration enforcement

HC 407

18th

NHS nursing workforce

HC 408

19th

Restoration and renewal of the Palace of Westminster

HC 549

20th

Tackling the tax gap

HC 650

21st

Government support for UK exporters

HC 679

22nd

Digital transformation in the NHS

HC 680

23rd

Delivering carrier strike

HC 684

24th

Selecting towns for the Towns Fund

HC 651

25th

Asylum accommodation and support transformation programme

HC 683

26th

Department of Work and Pensions Accounts 2019–20

HC 681

27th

Covid-19: Supply of ventilators

HC 685

28th

The Nuclear Decommissioning Authority’s management of the Magnox contract

HC 653

29th

Whitehall preparations for EU Exit

HC 682

30th

The production and distribution of cash

HC 654

31st

Starter Homes

HC 88

32nd

Specialist Skills in the civil service

HC 686

33rd

Covid-19: Bounce Back Loan Scheme

HC 687

34th

Covid-19: Support for jobs

HC 920

35th

Improving Broadband

HC 688

36th

HMRC performance 2019–20

HC 690

37th

Whole of Government Accounts 2018–19

HC 655

38th

Managing colleges’ financial sustainability

HC 692

39th

Lessons from major projects and programmes

HC 694

40th

Achieving government’s long-term environmental goals

HC 927

41st

COVID 19: the free school meals voucher scheme

HC 689

42nd

COVID-19: Government procurement and supply of Personal Protective Equipment

HC 928

43rd

COVID-19: Planning for a vaccine Part 1

HC 930

44th

Excess Votes 2019–20

HC 1205

45th

Managing flood risk

HC 931

46th

Achieving Net Zero

HC 935

47th

COVID-19: Test, track and trace (part 1)

HC 932

48th

Digital Services at the Border

HC 936

49th

COVID-19: housing people sleeping rough

HC 934

50th

Defence Equipment Plan 2020–2030

HC 693

51st

Managing the expiry of PFI contracts

HC 1114

52nd

Key challenges facing the Ministry of Justice

HC 1190

53rd

Covid 19: supporting the vulnerable during lockdown

HC 938

54th

Improving single living accommodation for service personnel

HC 940

55th

Environmental tax measures

HC 937

56th

Industrial Strategy Challenge Fund

HC 941


Footnotes

1 C&AG’s Report, Investigation into the implementation of IR35 tax reforms, 2021–22, HC 1103, 10 February 2022

2 C&AG’s Report, paras 1.5, 1,7–1.8

3 Qq 70, 80; C&AG’s Report, paras 1.10–1.11

4 C&AG’s Report, paras 3–4

5 Q11; C&AG’s Report, para 16

6 Qq 11–12

7 Q13

8 Q28; C&AG’s report, para 10

9 C&AG’s report, para 11

10 Qq 28, 31

11 Qq 14, 16, 18–19

12 Q18

13 C&AG’s Report, para 3.8

14 C&AG’s Report, para 3.4

15 Q22; C&AG’s Report, para 3.6

16 Qq 40, 43

17 Qq 44–45

18 Qq 46, 48

19 ICAEW written evidence dated 11 February 2022

20 Q55

21 Q22

22 Qq 62, 64

23 Q56; C&AG’s Report, paras 4.12–4.13

24 Q15

25 C&AG’s report, paras 4.13–4.14

26 Qq 15, 17

27 Contractor Calculator written evidence dated 12 February 2022; C&AG’s report, para 19

28 Q40

29 C&AG’s Report, paras 3.7, 5.13

30 C&AG’s Report, para 3.4; House of Lords Economic Affairs Committee Finance Bill Sub-Committee Off-Payroll working: treating people fairly, 1st Report of Session 2019–21, HL Paper 50, 27 April 2020

31 Q40; C&AG’s Report, para 3.7

32 C&AG’s Report, para 3.9

33 Qq 40–41, 76

34 HMRC, Long term effects of the Off-Payroll working rules reform for public sector organisations, February 2022, para 1.35

35 Q75

36 Q25;

37 Q21; HC Committee of Public Accounts, BBC and personal service companies, Ninetieth Report of Session 2017–19, HC 1522, April 2019

38 C&AG’s Report, para 3.7

39 Qq 25, 75

40 C&AG’s Report, paras 26b, 5.11

41 Q51

42 Qq 36, 37; C&AG’s Report, para 13

43 Q36

44 Q37

45 Q69; C&AGs’ Report, para 3.3

46 Qq 26, 65; C&AG’s Report, para 5.10

47 Q 39; Written evidence submitted by HMRC dated 10 March 2022

48 Q60

49 Q70; C&AG’s Report, para 1.11

50 Qq 59–61

51 Qq 59, 65; C&AG’s Report, para 5.10

52 Q65

53 Qq 81–82