Managed Service Companies (MSC): Application of the tax rules - MSC Offshore
Where the worker is resident in the United Kingdom and the relevant services are provided in the United Kingdom, the MSC is treated as having a place of business in the United Kingdom, whether or not it in fact does so. The practical consequence of this is that simply because the MSC is based “offshore” does not render the legislation inoperative. If an offshore MSC fails to apply the legislation, HMRC can determine the PAYE and NICs that should have been accounted for and if that sum cannot be recovered from the offshore MSC, HMRC would invoke the transfer of debt provisions (see ESM3525).
See also ESM3595.