Hi Debbie,
Personally I have no idea as to the rules of MLR and payroll, I do MLR on all clients regardless of the work I do for them. I've found that you start by offering a client one aspect of bookkeeping and then it builds to other types of work - so at least I know I'm covered.
I'd assume that MLR is needed. Payroll involves money transfers from your client to their employees and the HMRC, but the money that is transfered must have originated from somewhere. The due diligence required for MLR would (I assume) help to cover you if it turns out that the money doesn't originate where you think it does.
I suggest that you phone the ICB technical helpline, who will be able to give a difinitive answer.
Lucy
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