Caring and sharing

Two companies under common control operate in the care home industry. One company provides traditional care and the other provides domiciliary care (for the latter legislation dictates that this type of care cannot be provided by the same organisation as that providing the premises although related-party issues do not currently seem to present a problem).

Would there be any tax or National Insurance implications if the same staff were used for both?

Typically each home will have its own core staff but a number of staff will ‘float’ from home to home depending on daily staffing needs as well as more general management and training roles which are provided to cover all homes.

It is also feasible that each home – and thus company – will provide both types of care. Will sharing staff create any VAT issue given that at the moment ...