I am not sure what "squowse" thinks that his last contribution adds to the discussion. Incidentally, the following sentence is directly quoted from Tax Bulletin 45:
"One of the central questions in deciding whether the new rules apply to an engagement is to establish whether the worker would have been an employee of the client if engaged directly."
The fact that the words "an engagement" are used clearly imply that the rules apply to each individual client engagement, not to the totality of the service company's activities. So, as I said in my earlier contribution, the number of engagements is not directly relevant, even on the Revenue's view.
In any event, taking the Revenue's position as being gospel on contentious matters like this is a bit daft (unless, of course, it works to the advantage of the taxpayer). Their pronouncements are always, always, always - without exception - (emphasis clear enough?!)tendentious and frequently wrong. For example, they quote the case of Hall v Lorimer as if it was a case where their sweetly reasonable views were upheld in the face of unreasonable opposition by a recalcitrant taxpayer. Actually, the complete opposite is the truth.
The fact is that "categorisation" issues (and, by extension, IR35) are not apt to be dealt with by the unininformed or the uninitiated. As I said before, it is a shame that the rules are not more widely understood given their wide relevance.
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