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When contracting, agencies and end clients know this, which is why there is usually an uplift in the rate for contractors vs perm workers. The umbrella company holds the contract with the agency or end client, so funds received at this point belong to the umbrella. This is why deductions such as the umbrella fee, employers NIC, holiday pay and apprenticeship levy is then taken from the umbrella income before gross pay is calculated which is then liable for standard PAYE deductions. For a better explanation please look at Working through an umbrella company - GOV.UK (www.gov.uk)
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