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Output tax conundrum

15 March 2016
Issue: 4542 / Categories: Tax cases , Admin

Adecco UK Ltd and others (TC4743)

Tripartite arrangement on the supply of staff

The taxpayer provided recruitment services. It supplied temporary workers to clients. It accounted for VAT on the full charge paid by clients for the services of the temporary workers. This comprised the amount paid by the client representing the worker’s wages and the commission.

After the decision in Reed Employment Ltd (TC1069) in which the tribunal found that the employment bureau was not liable to account for VAT on the element of the charge representing the wages to be paid to the workers the taxpayer claimed a repayment.

HMRC rejected this on the basis that the taxpayer was liable to account for VAT on the full charge paid by the clients because it supplied the services of the non-employed temporary workers and was not supplying the service of introducing workers to its clients only.

The taxpayer said ‘control’ was a key issue. It...

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