
IR35 and the PEO model
Where the PEO model sits against IR35, and how employment, payroll and compliance responsibilities are shared

Operating through your own limited company under IR35 — status determinations, the deemed payment, and what the client now decides.
Since the off-payroll reforms, the end client decides status for engagements with medium and large businesses, and the fee-payer operates PAYE where the answer is inside. The company’s director no longer makes that call for those engagements.
Where the client is a small company, the original IR35 rules still apply and the determination remains the intermediary’s own responsibility.
Where the older rules apply and an engagement is inside, the company calculates a deemed employment payment at the year end and accounts for PAYE on it. It is a calculation, not an invoice, and it has its own deadline.
A company that only ever holds inside-IR35 engagements is administrative cost without the corresponding benefit. Where the mix is genuinely mixed, it usually still earns its keep.

Daniel Okafor
leads contractor payroll operations at Promultis
Daniel Okafor runs the payroll operation that pays several thousand contractors every week, and he built most of it. He joined Promultis from a large umbrella provider, where he was responsible for RTI submissions and auto-enrolment across a book of forty agencies. Daniel works closely with recruitment partners on onboarding, same-day payments and the reporting hirers need for their own audits. He writes about the practical side of contractor engagement — the parts that decide whether a worker stays past their first assignment.

Where the PEO model sits against IR35, and how employment, payroll and compliance responsibilities are shared

How a status determination statement is reached, who is responsible for issuing one, and what to do when you disagree with it

Reading an umbrella payslip line by line — assignment rate, employment costs, and the taxable pay you actually take home


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