PROCUREMENT: Does the cleaning / disinfection of temporary office and welfare facilities sit inside or outside of Construction Industry Taxation Scope?

Due to COVID-19 there is a requirement to address the cleaning and disinfection of temporary office and welfare facilities. Additional external (non-direct) resources are now required. If we are looking to procure such services from the market, do we also need to consider CIS taxation i.e. is this activity within scope or not.

Regulation FA04/S74 (2)(d) states that ‘internal cleaning of buildings and structures, so far as carried out in the course of their construction, alteration, repair, extension or restoration’ is within scope. This clearly relates to cleaning associated with the final permanent product as such; we are not looking to have them clean the final permanent product i.e. only temporary facilities to limit / mitigate COVID-19 transmission.

However, with regards to Site facilities - the exclusion of temporary structures from CIS does not apply to the erection of site huts, portable offices and similar facilities on building sites. These are considered to be integral to the main operations and their construction is caught.

Dependant upon whether the cleaning of temporary facilities is in or out of scope will dictate procurement route - potential NEC Shortform Subcontract for such services.

Thoughts appreciated.

Application of CIS is a specialist area and worth taking some specific advice.

However, I would expect that this would be considered within the scope of the CIS