Page 16 - People Group - Joint Employment Features, Advantages & Benefits

HMRC Confirmation Letter - Page 2
In my opinion, the guidance is stating that there can be no taxable supply (of staff) between
joint employers because the workers in question are each the employer’s own employees.
So, even when monies (thus potential monetary consideration) pass between them for
paying the workers – including salaries and resulting taxes - there is still no supply between
the joint employers, because the monies are related to paying their own workers. Put
another way, if the worker wasn’t paid by one of the joint employers, the other joint
employer(s) would be jointly and severally liable to pay the worker, so the monies in
question are the wages/related taxes and pensions.
xxxxxxxxxxxxxxxx xxxxxxxxxxxxxxx xxxxxxxxxxxxxx:
 xxxxxxxxxxxxxxx  xxxxxxxxxxxxxxx  xxxxxxxxxxxxxxx  xxxxxxxxxxxxxxx  xxxxxxxxxxxxxxx  xxxxxxxxxxxxxxx  xxxxxxxxxxxxxxx  xxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
If you have any further queries then do not hesitate to contact me Yours sincerely
XXXXX XXXXXXX
Investigator
To find out what you can expect from us and what we expect from you go to
www.gov.uk/hmrc/your-charter and have a look at ‘Your Charter’.
151835 2
To summarise, I consider that there is a joint employment given the conditions and contracts
provided. Remittances between the agency and PPL would be subject to guidance at
700/34 however only costs that can be associated with wages, related taxes, pensions and
statutory payments would be classified as outside the scope of VAT.
44 6.0
14 Version 2.0 2022