Is asbestos removal inside CIS?

Why people assume it is outside

Licensed asbestos work sits under its own regulatory regime, with its own licensing, notification and record-keeping duties. That separateness is what makes people assume it must also sit outside a construction tax scheme. It does not. The licensing regime and the CIS scope test are answering different questions, and the answer to one tells you nothing about the other.

What it means for the invoice

Because the work is in scope, a payment from a contractor to you for asbestos removal is a payment under the scheme. You need to be registered and verified or the deduction is taken at the higher rate, and the contractor has to include the payment on the monthly return.

Two practical consequences follow:

• The deduction base. Materials you directly incurred, consumable stores, plant hire and fuel other than fuel for travelling come out of the payment before the deduction is calculated. On licensed work the plant and consumables element is often substantial, so identifying it properly on the invoice changes the cash figure.
• The VAT reverse charge. The reverse charge takes its scope from the CIS definition of construction operations. Work inside CIS is normally inside the reverse charge too, unless your customer is an end user and has told you so in writing.

Disposal and tipping

The removal is the construction operation. What happens to the waste afterwards can be a separate supply depending on how the contract is written and who holds the disposal obligation. Where a single price covers both, the whole payment normally follows the construction operation. Where they are genuinely separate supplies, they can be treated separately — but that has to be real, and reflected in the contract before the work rather than split on the invoice afterwards.

This question is part of Accountants for demolition contractors, which covers the whole area.