The draft legislation, published in July 2025 and set to take effect from April 6, 2026, marks a fundamental re-engineering of the UK’s temporary labour market. At its core, the new Chapter 11 in Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) introduces a new and impactful concept: Joint and Several Liability (JSL) for unpaid PAYE tax and National Insurance Contributions (NICs) in umbrella company supply chains. This measure is HMRC’s direct response to a decade of widespread non-compliance and tax loss estimated at nearly £1 billion annually, primarily orchestrated by unscrupulous umbrella companies.
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