The government proposals contained in a government consultation document, The Taxation of Controlling Persons, requiring private sector employers to put senior level contractors who engage their personal service companies on their payroll has been much criticised. There are particular difficulties where an Agency is involved in the middle of a contractor and end user where there will inevitably be arguments over who is responsible for defining whether the contractor is a controlling person or not. No doubt the devil will be in the detail of the final legislation.