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HMRC internal manual

Construction Industry Scheme Reform Manual

The Scheme: construction operations: painting or decorating

CISR14600 Action guide contents

FA04/S74 (2)(e) says that the following operations are within the scope of the Construction Industry Scheme

  • ‘painting or decorating the internal or external surfaces of any building or structure’.

As it stands, this provision is straightforward. Painting is the application of a decorative or protective film to a surface. In practice, however, it may not always be obvious that this provision applies because the subcontractor or contractor presents the query in unfamiliar terms.

For instance, masonry undergoing restoration is sometimes sprayed with a sealant to prevent atmospheric deterioration. Similarly, a variety of applications are now in use to inhibit vandalism, graffiti or climbing. The application of these coatings may be given various names for technical or marketing purposes but, basically, the surface is being spray painted or coated with a protective film or special purpose paint.

Off-site work

Occasionally, items will need to be sent to specialist workshops for repair or restoration work, for example cupboard doors removed for French polishing or doors sent away to have existing paintwork stripped and gilding applied. If this work is carried out by a subcontractor in isolation, it will be outside of the scheme. However if the contract requires the subcontractor carrying out the work, to also remove or dismantle the items to be treated and/or to replace them on completion of the treatment, then all the work will fall within CIS.

Within CIS

  • paint application, including gilding or gold leaf work to the building or structure
  • varnishing
  • French polishing of fixed furniture or woodwork
  • certain types of damp-proofing treatments
  • ceiling masonry.

Excluded from CIS

  • pesticide spraying including insecticidal or pesticidal wood treatment
  • off-site French polishing.