When a senior HMRC officer says that those he trained on IR35 would be competent after three years and understand it after five years, and when judges are split in the recent tribunal decision in Paya Ltd TC07377 [2019], one wonders how many years it might take taxpayers, the private sector and general practitioners to grasp this area of complex tax law.

When IR35 changes to off-payroll working for private companies come into force in April 2020, private sector entities will bear the responsibility of assessing the employment status of workers/contractors they engage to work for them, among other requirements. This will inevitably present challenges.