Corporation Tax Act 2009 section 141A

Intermediaries providing worker's services to public sector

Section 141A allows intermediaries in the off-payroll working rules for the public sector to exclude certain payments from their trading profit calculations, preventing double taxation where a deemed direct payment has already been treated as employment income.

• Where a worker provides services to a public sector client through a chain of intermediaries, the fee-payer in the chain must account for income tax and NICs on a deemed direct payment to the worker
• An intermediary in that chain who receives a payment for the same services does not need to include that payment when calculating its trading profits for corporation tax purposes
• This exclusion only applies where a deemed direct payment has been treated as made under the off-payroll working rules for the public sector
• The "underlying chain payment" is the starting amount used to calculate the deemed direct payment, before deductions are made in the calculation steps