A labour-only subcontractor invoicing £10,000 banks £8,000, and before March 2021 the same invoice put £10,000 in the account with VAT to hand over later. Nothing improper has happened. Two separate rules changed in the same direction and they compound. This guide traces exactly where the money goes and then works through the seven fixes, in the order they are worth doing.
Guide · Updated August 2026
A VAT-registered, CIS-registered subcontractor invoices £10,000 of labour to a VAT-registered main contractor who is not an end user.
Pre-March 2021 the same invoice was £12,000 gross, £2,000 CIS deducted, £10,000 banked — with £2,000 of VAT to pay over up to four months later. The business now receives 20% less cash on the same work, and if it is still budgeting on the old rhythm it is structurally short.
Before 1 March 2021 a subcontractor held its output VAT for up to four months between invoice and return. A great many businesses were quietly using that as working capital without ever describing it that way. The domestic reverse charge removed it from the cycle for good. There is no arrangement that brings it back — it has to be replaced from somewhere else.
A sole trader recovers CIS deductions only through Self Assessment after the tax year ends. A company can offset only against PAYE, NIC, student loan repayments and the CIS it has deducted from its own subcontractors — and with a small payroll there is not enough to absorb it, so the excess waits for the year end. HMRC is explicit that no in-year repayments or other set-offs are permitted except in liquidation or administration.
So for a labour-only business the deduction base is close to 100% of turnover, and the recovery point is up to twelve months away.
With no output VAT on sales but input VAT on materials, fuel, plant hire and overheads, your VAT returns now tend to produce refunds rather than payments. That is not a problem in itself — it is an opportunity most subcontractors have not taken, and it is fix number two below.
This is the whole 20%, permanently. Turnover of £30,000 net of VAT and materials is a low bar for a full-time trade; the compliance test is the real hurdle, and since 6 April 2024 VAT compliance is part of it. From 6 April 2026 the consequences of losing it became severe: immediate cancellation where the business knew or should have known payments were connected with fraudulent evasion of tax, liability for the lost tax, a 30% penalty extending to directors personally, and a five-year bar on reapplying. So the instruction is two-part: get it, then protect it. The gross payment status guide covers all three tests.
On £180,000 of labour invoicing, gross status is around £36,000 that stops being locked up. Nothing else on this list is close.
It converts a quarterly refund into a monthly one and pulls roughly a month and a half of average refund permanently forward. It is a five-minute change with no downside for a repayment trader, and it has the side benefit of keeping your VAT filing frequent — which, since April 2024, is part of your CIS compliance record too.
Absent notification, the reverse charge is the default, and applying VAT wrongly creates an error on both sides of the invoice. One email per customer, once, kept on file. Do it for every customer rather than the ones you are unsure about, because the ones you are sure about are where the assumptions hide.
Materials you directly incurred reduce the CIS deduction base. On the same £10,000 invoice, £3,000 of properly evidenced own-bought materials cuts the deduction from £2,000 to £1,400 — £600 of cash on one invoice. Materials reimbursed by the contractor, or bought on the contractor's account, give no reduction at all because you have not directly incurred them.
Also remember what stays in: travel and subsistence are subject to deduction. Recharging mileage does not shelter it. Run your jobs through the CIS deduction calculator to see the difference materials make.
Deductions offset in-month against PAYE and NIC through the employer payment summary are cash retained now, not a refund claimed next year. This is the mechanism that makes a company genuinely better on CIS cash flow — and its absence is why incorporating a one-person labour-only business with a £12,570 director's salary changes very little. See trades payroll.
With reverse-charged sales there is little VAT-inclusive turnover to apply a flat rate to, and low relevant goods spend risks the 16.5% limited cost business rate. If you joined before March 2021 and your work is now mostly subcontract, the scheme is probably costing you. It remains useful for a trade selling direct to domestic customers. The VAT rates guide has both sector rates and the thresholds.
They are a tax asset. If they are not appearing as one on your balance sheet, the CIS records and the payment and deduction statements are the first thing to reconcile — and a subcontractor who cannot produce a year of statements usually turns out to be owed more than they thought. Every statement should show the gross amount paid, the materials that reduced the deduction, and the deduction itself. Missing statements are missing money.
The businesses that do not have this problem tend to share five habits, none of them clever:
None of that requires a finance director. It requires the records to be current, which is the same thing Making Tax Digital now requires anyway — so most trades are being pushed towards the right habit by the compliance regime whether they like it or not.
What has changed on CIS and the reverse charge, the dates coming up, and one number worth checking on your own jobs. No spam, unsubscribe any time.
Two separate rules acting on the same invoice. Under the VAT domestic reverse charge you invoice a VAT-registered contractor with no VAT added, so the £2,000 of output VAT you used to hold for up to four months never reaches your account at all. Then the contractor deducts CIS at 20% from the whole £10,000, because on labour-only work there are no materials to exclude, so another £2,000 goes to HMRC. You bank £8,000 on a £10,000 sale. Before March 2021 the same job produced £12,000 gross, £2,000 deducted and £10,000 banked, with the VAT payable later — which is why businesses budgeting on the old rhythm are structurally short.
Apply for gross payment status. There are three tests: the business test, which just requires construction work run through a bank account; the turnover test, which is £30,000 for a sole trader measured on the last twelve months excluding VAT and materials, or £30,000 per partner or relevant person for a partnership or company with a £100,000 total alternative; and the compliance test, which requires CIS, PAYE, income tax, corporation tax and — since 6 April 2024 — VAT obligations all to have been met on time. On £180,000 of labour invoicing, gross status frees around £36,000 of working capital permanently.
If your sales are reverse-charged you are probably in a repayment position, and in that case yes. With no output VAT on sales but input VAT on materials, fuel, plant hire and overheads, your returns naturally produce refunds — and monthly returns convert a quarterly refund into a monthly one, permanently pulling roughly a month and a half of average refund forward. There is no real downside for a repayment trader, and a useful side effect: since April 2024 VAT compliance forms part of the gross payment status test, so filing twelve times a year keeps the habit frequent rather than letting a quarterly deadline slip past unnoticed.
Yes, measurably, provided you directly incur the cost. CIS deductions are only taken from the part of the payment that does not represent materials the subcontractor has itself paid for. On a £10,000 invoice with £3,000 of your own properly evidenced materials, the deduction falls from £2,000 to £1,400 — £600 more cash on a single invoice. If the contractor buys the materials or reimburses you for them, you have not directly incurred them and no reduction is due. Keep the purchase invoices, because HMRC expects the contractor to seek satisfactory cost information and to estimate the materials figure if it looks inflated.
Only if the company runs a genuine payroll. A company cannot claim CIS deductions on its corporation tax return; it offsets them monthly through the RTI employer payment summary against PAYE due, NIC due, student loan repayments and the CIS it has deducted from its own subcontractors, with any excess refunded or set against corporation tax after the year end. With staff, that monthly offset is real cash retained now. With only a £12,570 director's salary there is nowhere near enough PAYE to absorb the deductions, so the money still waits until after 5 April — meaning incorporation on its own does not solve the problem. Gross payment status does, in either structure.
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One short email: what has changed in CIS and construction VAT, the dates coming up, and one number worth checking on your own invoices. No spam, unsubscribe any time.