There is also a lack of HMRC guidance around the final legislation and the absence of the updated CEST tool which adds to uncertainty for businesses in implementing these rules.
In addition, planning for changes in the labour market in terms of supply, costs and administration is going to take time and preparation.
With so many variables for business, it is hard to predict the impact of these changes.
Will we see less contractors? Will contractor rates increase? Will costs be passed on to the general public? How will the HMRC support businesses? Will the promise on historical tax enquiries hold firm?
This is yet another item on the business agenda to watch and wait, while preparing for a worst case scenario from April 2020 goes ahead as it currently stands.
Of course, if businesses are engaging a contractor on a project that will run on past 5 April, they should seek advice now.
Dawn Register is a partner in Tax Dispute Resolution at accountancy and business advisory firm BDO