SDC Issues

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In that scenario and with these models hoping to be out of scope of the definition, SDC wouldn’t be a non-issue because there would be scope for T&S (and other expenses) to be offset on an ongoing basis through the scheme’s PAYE process. However, given the very high hurdle that HMRC have set for a worker to be deemed to genuinely lack SDC and therefore be entitled to T&S, and given that T&S claims make up the majority of claims made through an umbrella, even a new non-salary sacrifice umbrella model is unlikely to offer much more tax-efficiency come April than a salary sacrifice-type umbrella that is nothing more than standard PAYE. This is precisely the reason I don’t think these new umbrella models will have much of a shelf life.