In our last newsletter we discussed the introduction of the Criminal Finances Act and what this meant for agencies. Just to recap the aim of this legislation by the Government is to make it much easier to convict companies where their employees have facilitated tax evasion. The CFA is designed to ensure that companies look more closely at their employees' actions and to take responsibility for ensuring that their supply chain is operating compliantly.
Our advice to agencies whose consultants refer their contractors on to third parties is to make sure that you know who you are dealing with. The best way to do this is to have a PSL comprising companies that you know and trust. Putting together a PSL is one thing but making sure it works properly is another. Here are our top tips to make sure PSLs work:
1. Monitor placements vs referrals - if there is a big discrepancy you may have a leakage problem
2. For PSCs capture the accountant's name when you issue a contract - Agencies know the names of umbrellas that their contractors use (because they pay them) but are sometimes blind to schemes that PSC contractors use. By capturing names you may see a pattern of referrals prompting you to look at the accountant.
3. Hold regular meetings with your chosen providers - review performance and share referral information.
4. Contact non-approved providers - if you identify a company dealing with a number of your contractors ask how they generated the business.
5. Check the marketing merchandise on consultants' desks - this may give you a clue who your consultants are talking to.
6.Take a hard stance with non-conforming staff members - be clear what is acceptable and what is not.