Umbrella company

but they were also employing them.

So that, I think, would make them an umbrella company and therefore subject to all the same regulation and the joint and several liability.

Is that right? Yes.

I mean, so there's a definition of an umbrella company under the joint and several liability legislation.

But I mean, yes, effectively, if you employ someone, you supply them to work for somebody else.

I'm sort of summarising here, but broadly speaking, that makes you an umbrella company.

And If you have what is perceived to be a payroll bureau, so they are running PAYE in respect of agency workers and also employing them on a contract of employment, it's highly likely that they would amount to an umbrella company under the definition.

And I think just while we're on that topic, it's important for agencies to recognize that this definition that we now have of an umbrella company, which didn't exist before, there was never really a formal legal definition of an umbrella.