Sir, We a t the Na t iona l Spec ia list Contractors Council have written to the Inland Revenue raising our concerns over the proposed new business reality test to establish employment status.
With a membership of over 7,000 bu s ine sse s , wh ich in turn engage thousands more subcontractors, the NSCC represents those most likely to be affected directly by any changes in the rules to establish employment status.
The main problem with the existing system is not simply that the criteria for establishing employment status are too complex, but that the Inland Revenue has been inconsistent in applying the criteria and has not committed adequate resources to ensuring their implementation.
The current system is complex and has evolved over a number of years. The NSCC supports the principle of a clear set of rules applied consistently . . . but not at the cost of fairness.
The proposals require not only the added administrative burden of VAT registration for all subcontractors, irrespective of size, but also other qualifications, which would result in having employment status imposed on thousands of genuine self-employed subcontractors.
The NSCC hopes to continue to work with the Inland Revenue and other industry representatives to achieve a test for establishing employment status that is clear, simple and, above all, fair.
Sneha Doshi NSCC policy adviser London EC1