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Bricklaying is construction of a building, so it is inside CIS. Two things then decide your position: who buys the bricks, because contractor-supplied materials give no reduction at all, and whether your gang is genuinely self-employed.

UK trades and construction
In scope
ConstructionOf buildings and structures, permanent or not
Materials
Who bought themContractor-supplied gives no reduction
Watch
Gang statusThe exposure sits with whoever engages them

Bricklayers · CIS scope

In scope, then two questions that decide everything

Construction, alteration, repair and extension of buildings or structures — permanent or not — is a construction operation, so bricklaying, blockwork and the substructure with it are inside CIS.

Who buys the materials? On most bricklaying work the main contractor supplies bricks, blocks, sand and cement. That is normal and it removes the working-capital burden — but it also means you have not directly incurred the cost, so no reduction to the deduction base is due and the deduction is charged on your whole invoice. Where you do buy materials, evidence them: HMRC's instruction to the contractor where a figure looks overstated is to ask for satisfactory cost information and, if it is withheld or looks inflated, to make a reasonable estimate — and the contractor carries the responsibility for that estimate being reasonable.

Is the gang self-employed? This is the exposure that matters most on this trade, and it does not sit with the bricklayers.

Why CIS registration proves nothing

CIS 340 is explicit: for a contract to be within the scheme it must not be a contract of employment; it is for the contractor to consider employment status when a subcontractor is first engaged; and the fact somebody has worked self-employed before is irrelevant — it is the terms of the particular engagement that matter. A gang supplied with all materials and plant, working set hours under direction, on one site, for one contractor, with no right of substitution and no financial risk, is very likely employed at common law. A 20% deduction is a fraction of the PAYE, employee National Insurance and 15% employer National Insurance that would have been due.

And the two things that are true whatever the trade

The deduction is charged on the payment less materials you directly incurred, consumable stores, fuel other than fuel for travelling, plant hire, the cost of manufacture or prefabrication, and the VAT you charged. Travel and subsistence stay in. And where the contractor buys the materials and recharges them, you have not directly incurred them, so no reduction is due at all.

If the deduction is costing you cash, gross payment status is the fix rather than a workaround — the turnover test is £30,000 of relevant payments net of VAT and materials for a sole trader, and the compliance test, which since 6 April 2024 includes VAT, is the part that needs preparing for.

Quick answers

Frequently asked

I run a gang. Am I a contractor as well as a subcontractor?

Yes, on both counts at once. You are a subcontractor on what the main contractor pays you and a contractor on what you pay the gang — so you suffer a deduction on money in, and you must verify, deduct, file a return by the 19th, issue statements in the same fourteen days and pay over by the 22nd on money out. Both sets of duties run simultaneously, which is why the administration feels heavier than the turnover justifies. From 6 April 2026 it got slightly heavier again: a mainstream contractor must file a nil return or notify inactivity even in a month when the gang was not paid.

What is the real risk if HMRC says my gang were employees?

The exposure is the PAYE and National Insurance that should have been operated, and it falls on the engager rather than the worker. Employer National Insurance alone is 15% on earnings above a £5,000 secondary threshold in 2026/27, on top of the income tax and employee National Insurance that should have been deducted. The 20% you did deduct is credited but does not come close. And since 6 April 2026 the umbrella company rules push PAYE responsibility up the chain to the agency, or to the end client where there is no agency.

Does it help me that the contractor buys the bricks?

For cash on the day, yes — you are not funding the merchant account. For your CIS deduction, no. Materials only come out of the base where you directly incurred them, so contractor-supplied or recharged materials give no reduction. On a job where materials are a large share of the value that difference is substantial, and it lasts until you recover the deduction after the year end. If you want the materials to reduce your deduction, buy them on your own account and keep the purchase invoices in your own name.

Is scaffolding I provide part of my CIS invoice?

Erecting scaffolding is expressly a construction operation, so it is in scope. Separately hired scaffolding is a different matter for VAT — it sits in the builders' block of non-qualifying goods and stays standard rated even alongside zero-rated new- build work. So one site can carry a zero-rated bricklaying supply and a standard-rated scaffolding hire. Erection labour follows the rate of the construction work; the hire period does not. Splitting the two on the invoice is what makes that defensible.

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