For institutions and other entities that are public authorities for Freedom of Information Act purposes, guidance recently published by HMRC has confirmed that off-payroll working status determinations made prior to 6 April 2020 will only be valid for engagements continuing after this date if they meet new legislative requirements. These require the client institution to provide reasons for the decision and pass them to both the individual and any third party the client contracts with.
This could lead to tax liabilities if institutions do not take action. For further information about the changes and steps to take, see our detailed article here.