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For recruitment agencies and employment businesses

The tax sits with the fee-payer. The file has to sit somewhere too.

A statement that reaches you and stops there is one you are paying the deductions on.

What amount is PAYE operated on?

For an inside-IR35 engagement the fee-payer runs the statutory steps of s.61Q ITEPA 2003 on each payment to the worker's company (HMRC guidance: ESM10028). Free to use; nothing is stored.

Employer (secondary) Class 1 NICs and the apprenticeship levy are funded by the fee-payer on top of this amount.

Why it stops here

HMRC's published position is that those costs cannot lawfully be deducted from a fee that has been agreed; a lower rate can only be negotiated before terms are agreed. This walkthrough applies no tax or NIC rates deliberately: rates change every April, and a stale rate prints wrong money silently.

Free, no sign-up, nothing stored. Employer NICs and the Apprenticeship Levy sit on top of this figure, not inside it.

The statement travels down. Stop passing it on and the tax stops with you.

You are usually the party that pays the worker's company, which makes the deductions yours the moment a statement lands and says inside. Where you sit is not a contract type — it is computed, per engagement, from the chain you recorded.

  1. End client

    Issues the statement

    Only the client can make it (s.61NA), and it is not a statement at all without the reasons behind the conclusion.

  2. Agency — you

    Receives, then passes it on

    Receipt is your own fact. Where the statement came from a Nebula client, your click on it records the date against your assessment — nothing re-keyed, nothing remembered.

  3. Worker's company

    Gets their copy

    The worker sees the conclusion and the reasons, and can make representations against it — which starts a 45-day clock on the client, not on you.

A real chain can be longer than three. Every party in it has to pass the statement to the next one, and the party that stops passing it on is the one HMRC treats as keeping responsibility for the tax and NICs (ESM10013). Nebula computes where you sit for each engagement from the chain you recorded — agency, end client or watch-only — rather than assuming it from a contract type, and shows the point at which the duty would land on you before it does.

A receipt you clicked beats a date you typed

Where the statement above you came from an organisation using Nebula, opening it offers to record the receipt straight into your own assessment — who it came from, and the date, taken from your visit. No re-keying, and no argument later about when it actually arrived. The offer appears only for the party the statement was addressed to: the worker's copy is not a chain receipt, and a recipient page is a statutory document before it is anything of ours.

Since 6 April 2026, umbrella PAYE is your problem

Where an umbrella company in the chain employs the worker, responsibility for accounting for PAYE and Class 1 NIC on that worker's pay sits with the recruitment agency — the end client where there is no agency — and HMRC can pursue that party in the first instance for payroll taxes a non-compliant umbrella never remitted.

Read it at source: PAYE rules for labour supply chains that include umbrella companies from 6 April 2026 and Responsibilities for employment businesses working with umbrella companies (GOV.UK).

Which chains carry an umbrella

Each engagement records whether an umbrella is in the chain, who vetted it and when.

Remittance re-checks, dated

Checks run on a cycle and land in the diary. That interval is our practice default, not a statutory one — and the product says so rather than implying law.

Where the duty actually lands

Agency, end client, or watch-only — computed from the chain you recorded, not assumed from a contract type.

Across the whole book, not one contract at a time

“They’re with a managed service provider” is not a reason no statement arrived

Three chapters of Part 2 ITEPA can reach the same engagement, and they do not yield to each other in the same direction. Where the off-payroll rules and the MSC legislation could both apply, Chapter 10 takes precedence.

  • An MSC in the chain does not move the duty to determine, or the statement, away from the client — so one is still owed to you.
  • Below a small client, where Chapter 8 would otherwise govern, the MSC legislation wins instead — and under it there is no status test to pass and no “outside” answer available.
  • Nothing here decides whether a company is an MSC: that is four conditions in s.61B(1), the last turning on whether a provider is “involved with” it. The product asks the question and reports what follows.
Order
Ch10 › Ch9 › Ch8
Basis
ESM10004
We decide
Nothing — we ask

The enquiry bundle, the diary and the document verification that sit under all of this are shared with the other two roles \u2014 the hub describes them once.

Pricing

Pay per assessment, or put the whole book on one bill. Ex VAT; VAT is added at checkout or reverse-charged against your VAT number.

Pay as you go

One fee-payer assessment at a time. No subscription, no minimum.

£29 + VAT per assessment
  • Unlimited seats
  • Pay per assessment
  • Shared team book and chain log

Unlimited

Every assessment, the chain log and the team, on one bill.

£249 + VAT / month
or £2490 + VAT / year£249 a month, two months free
  • Unlimited seats
  • Unlimited assessments
  • Shared team book and chain log

What an enquiry asks, and what a determination on its own can answer

A verdict is one line. These are the questions that come years later, when the person asking them was not in the room.

What did you conclude, and why?
A determination, with reasons
The same — versioned, with the settled facts frozen at affirmation
How did you know how the work actually runs?
The answers someone typed once
The manager's account AND the worker's, with the recorded reason wherever they differed
Who did you give the statement to, and when?
Not tracked — you kept the email
Delivery dates, and receipt acknowledged by the recipient's own click
Someone disagreed. When did you answer?
Your own diary, if you kept one
45 days beginning with receipt, on the clock, with the answer recorded
Is this still true a year later?
Re-run it and hope you remember
Dated reviews on a cycle, and a flag when the worker's account drifts
Can you show the document is unaltered?
A PDF that could say anything
A document number and SHA-256 hash anyone holding it can verify
HMRC has written. How long to assemble the file?
Days of digging through inboxes
One click — ten indexed sections, gaps stated rather than hidden

Nebula provides software and AI-assisted decision-support. It is not regulated financial, tax or legal advice, and there is no human review step behind its output — what the tool produces is a recommendation you decide on. Under s.61NA ITEPA 2003 the status determination statement is the end client's own statement. See how we earn trust.

IR35 for recruitment agencies | Nebula IR35