HMRC’s Employment Status & Intermediaries (ES&I) team has issued letters to all Police Forces, asking them to check the employment status of their Forensic Medical Examiners (FMEs) and any other workers not on the payroll. HMRC has requested information regarding off payroll workers paid in the current year, and also the previous six tax years going back to 6 April 2017. PSTAX can support clients with gathering the relevant information required to respond to HMRC, and where required, make a disclosure.
What information has HMRC asked for?
Unlike the recent LAUPSTREAM1 campaign aimed at local authorities, which HMRC considers to be ‘educational’, this Police campaign is compliance-focused. HMRC has advised that it considers there is a risk with FMEs, which it believes are likely to be employed for tax purposes. However, whilst there is an emphasis on FMEs there is also a requirement to review all ‘other workers’ not currently on the payroll. Some of the Police Forces we have already spoken to have only looked at the FMEs they have engaged and responded on this basis, and we expect HMRC will come back to those Forces to request further information.
HMRC has asked Police Forces to advise if they have to make a disclosure and/ or to explain why they do not believe their FMEs, or other workers should be on the payroll. And a lot of detailed information about the workers has been requested from HMRC.
Therefore, this is far more wide-reaching than the LAUPSTREAM1 campaign and requires that Police Forces review the status of workers paid off payroll currently and in the past.
The letters we have seen are dated 1st August and gave only 30 days to reply to HMRC otherwise a formal compliance check will be opened (though the standard Compliance Check information sheets were enclosed with the letters).
We expect that HMRC is likely to be pragmatic and flexible to some extent. The 30-day deadline was for you to make initial contact with HMRC and acknowledge receipt. However, it will be necessary to undertake a detailed review of workers paid off-payroll, so we strongly recommend that all Police Forces consider taking professional advice to do this and to manage the process with HMRC.
Ensure your Police Force’s Employment Status Compliance
HMRC has requested a lot of detailed information as part of this compliance exercise.
PSTAX can support Police Forces in:
- Guiding them to undertake the necessary work to provide HMRC with the information required.
- Liaising with HMRC on behalf of the Force to notify it of the progress being made.
Once the relevant information has been gathered, PSTAX will help to agree a final response to HMRC with sufficient detail to fully respond to HMRC’s specific questions.
If you would like to find out more about this campaign, and the information requested by HMRC, feel free to get in touch with us to arrange an initial discussion on Teams.