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HMRC internal manual

Labour Provider Guidance

Interventions: education and due diligence: end users: end user - a suggested definition

“Any business that is in a supply chain and is using another business to obtain their temporary workforce, i.e. a Labour Provider (LP)”

If there is a risk or perceived risk HMRC is duty bound to address this. As the risk varies from case to case, there is no definitive guidance but whatever method is adopted needs to be both legal and proportionate to the tax at risk. Labour providers have been identified as a high risk category trade sector. This may necessitate a vigorous approach to ensure any tax at risk is protected.

If a Labour provider is in a supply chain there will be an element of risk in the tax declarations. The more complex the supply chain the greater the potential risk of tax leakage. Until this risk is tested or audited neither the extent of the risk will be known nor will the amount of control or intervention required by HMRC