Income Tax (Earnings and Pensions) Act 2003 section 59

Provisions applicable to multiple intermediaries

Section 59 deals with the rules that apply when there is a chain of more than one intermediary between a worker and a client in an engagement caught by the intermediaries legislation (commonly known as IR35).

• Where multiple intermediaries are involved in a single engagement, all of them are jointly and severally liable for PAYE on any deemed employment payment — unless an intermediary has received no payment or benefit from the arrangement
• Where payments or benefits pass from one intermediary to another in the chain, the deemed payment calculation is adjusted to prevent the same income being counted twice
• Apart from the joint liability and double-counting rules, the intermediaries legislation applies separately to each intermediary in the chain
• A "relevant intermediary" is one that meets the conditions set out for companies, partnerships or individuals under sections 51, 52 or 53 of the Act