Agencies, Compliance & Governance

A Compliant Payroll Partner for Recruitment Agencies

We provide outstanding service

M&S On-Time Services Ltd provides structured payroll solutions designed to support recruitment agencies operating within regulated labour supply environments.

We support three engagement structures:

  • PAYE Umbrella Employment
  • CIS Self-Employed Subcontractor Payment Processing
  • IR35 / Off-Payroll Working (PSC engagements)

Our approach is built around transparency, governance, and legislative alignment.

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PAYE Umbrella Model

Under our PAYE umbrella structure:

  • Workers are employed by M&S On-Time Services Ltd
  • Assignment rates are agreed between the agency and M&S
  • Employer costs are transparently accounted for
  • Gross taxable pay is calculated in line with HMRC guidance
  • PAYE tax and National Insurance are deducted and reported via RTI

This model is typically appropriate where supervision, direction, and control are present.

We operate a straightforward PAYE model without artificial remuneration structures.

CIS Self-Employed Payment Services

M&S provides CIS subcontractor payment processing on behalf of clients where a genuine self-employed relationship exists.

Under this model:

  • The subcontractor is not employed by M&S
  • M&S acts as a payment intermediary
  • CIS deductions are applied in accordance with HMRC verification
  • Monthly CIS returns are submitted as required
  • Deduction statements are issued to subcontractors

Employment Status Considerations

Employment status must be determined correctly by the engaging parties.

Where working arrangements reflect employment indicators (such as supervision, direction, and control), PAYE engagement may be more appropriate.

M&S does not promote or facilitate false self-employment arrangements.

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IR35 / Off-Payroll Working (PSC Engagements)

Where contractors operate through a Personal Service Company (PSC), IR35 legislation may apply.

Under the off-payroll working rules:

  • The end client is responsible for determining IR35 status (in medium/large private sector organisations)
  • A Status Determination Statement (SDS) should be issued
  • Where the engagement is “inside IR35”, PAYE tax must be applied

M&S may support payment processing for PSC engagements where:

  • A valid SDS has been issued
  • The fee-payer responsibilities are clearly defined
  • PAYE is applied where required

M&S does not make IR35 status determinations on behalf of clients unless formally engaged to do so.

We do not facilitate non-compliant IR35 avoidance arrangements.

Governance & Risk Controls

M&S maintains a documented compliance framework covering:

Responsibility for site operations remains with the client controlling the workplace.

Criminal Finances Act 2017

M&S operates procedures designed to prevent the facilitation of tax evasion.

We refuse to engage in non-compliant remuneration or artificial structures.

Modern Slavery & Labour Standards

We take proportionate steps within the scope of our business to reduce exploitation risk.

Data Protection & GDPR

M&S processes personal data in accordance with UK GDPR and the Data Protection Act 2018.

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PAYE & HMRC Compliance

  • RTI submissions
  • Correct tax and National Insurance deductions
  • Transparent employer cost accounting
  • National Minimum Wage monitoring
  • Clear itemised payslips

CIS Compliance

  • RTI submissions
  • Subcontractor verification
  • Correct deduction application
  • Monthly CIS reporting
  • Clear subcontractor statements
  • Record retention

IR35 / Off-Payroll Controls

  • Recognition of SDS requirements
  • Clear fee-payer identification
  • PAYE processing where required
  • No promotion of IR35 avoidance structures

Our Position on Tax Avoidance

M&S operates procedures designed to prevent the facilitation of tax evasion.

M&S On-Time Services Ltd:

  • Does not operate loan schemes
  • Does not use offshore remuneration arrangements
  • Does not engage in disguised remuneration
  • Does not promote artificial tax avoidance
  • Does not facilitate IR35 avoidance structures

All PAYE payments are processed through standard payroll.

All CIS deductions are applied in accordance with HMRC regulations.

All IR35 engagements follow off-payroll legislation.

Clarification of Role

We take proportionate steps within the scope of our business to reduce exploitation risk.

  • Supervise workers
  • Control assignments
  • Determine working practices
  • Manage site health & safety

Operational responsibility remains with the client controlling the workplace.

Compliance Documentation Available

Agencies may request:

  • Insurance certificates
  • Policy summary pack
  • Modern Slavery Statement
  • Gender Pay Gap Report (if applicable)
  • CIS compliance overview
  • IR35 process overview
  • PAYE compliance statement

For compliance enquiries:

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