Why timing is the central point for limited companies

Every CIS deduction is an advance payment towards the subcontractor's eventual tax bill. For a sole trader, the route back is through Self Assessment after the tax year. The 2026/27 tax year does not end until 5 April 2027, and the return for it is not due until 31 January 2028, so a deduction suffered in April 2026 cannot be reclaimed until the year-end return is filed. A sole trader who waits until the filing deadline recovers that April 2026 deduction around 22 months after it was taken. Even an early filer is waiting roughly a year on the earliest deductions in the year.

A limited company has a different option. Because it runs a PAYE scheme, it sends HMRC a payroll remittance every month. The CIS rules allow the company to reduce that remittance by the amount of CIS it has suffered in the same tax month, using the Employer Payment Summary (EPS). Recovery happens in a 30-day cycle rather than at the year end.

This post covers the practical steps, a worked month-by-month example, what happens when CIS deducted exceeds PAYE due, and how the two routes compare. The full EPS filing mechanics, deadline detail and year-end excess credit treatment are covered in our guide to how CIS limited companies reclaim deductions in real time.

The labour-only rule: what goes on the EPS

CIS deductions apply to the labour element only. Materials are excluded. On a £10,000 invoice with £8,000 labour and £2,000 materials, the 20% deduction applies to the £8,000 only, giving £1,600, not £2,000. The EPS CIS suffered field takes the amount actually deducted, read from the CIS deduction statement. Entering the gross invoice value produces an overstated offset and a mismatch with the contractor's CIS300 return.

Month-by-month worked example

A single-director limited company registered as a CIS subcontractor, carrying out groundworks. Gross CIS income is £8,000 a month (labour only), deducted at 20%, so £1,600 withheld each month. The company has one part-time employee.

Month CIS deducted from company (£) PAYE/NIC due before offset (£) Net payable to HMRC after EPS offset (£) Surplus CIS credit carried forward (£) Running cash-flow benefit vs sole-trader route (£)
July 2026 1,600 2,000 400 0 1,600
August 2026 1,600 2,000 400 0 3,200
September 2026 1,600 1,200 0 400 4,800

In July and August the PAYE/NIC bill exceeds the £1,600 CIS credit, so the company pays the £400 difference and retains the £1,600 that would otherwise sit with HMRC. In September the PAYE bill drops to £1,200 (the employee is on reduced hours), so the £1,600 credit covers it in full and £400 carries forward.

By the end of September the company has recovered £4,800 across three months via the EPS offset. Under the sole-trader route all £4,800 would still be with HMRC. The PAYE figures include director income tax, employee Class 1 NIC and employer NIC (charged at 15% on earnings above £5,000 from April 2025). The example is illustrative; the actual figures depend on the company's payroll structure.

When CIS deducted exceeds PAYE due: the carry-forward and the year-end refund

September in the example above produced a £400 surplus. In practice, a company with lower payroll, or one that has grown its CIS income relative to its PAYE obligations, may accumulate a larger carry-forward over the year. The EPS accumulates the credit month by month and it does not expire during the tax year.

At 5 April, any credit that has not been absorbed against PAYE and NIC during the year becomes the year-end excess. There are two outcomes, and they are not mutually exclusive.

Offsetting the excess against Corporation Tax

CIS deductions are advance payments of Corporation Tax, not income tax. The excess credit sits on the company's CT account and reduces the CT liability for the same accounting period. Corporation Tax rates for 2026/27 are 19% on profits up to £50,000 and 25% on profits over £250,000, with marginal relief between. The CIS credit reduces the cash CT payment pound for pound. It does not alter the company's taxable profits: the CT computation runs on trading income, allowable expenses and capital allowances as normal, and the credit is applied to the resulting bill.

Receiving a cash refund from HMRC

Where the excess CIS credit exceeds the CT liability, HMRC refunds the balance in cash. The company requests this via the final EPS and the CT600 process. HMRC targets processing within 25 working days once the claim is submitted. Discrepancies between EPS figures and what contractors reported on their CIS300 returns are the single biggest cause of delays, so reconciling deduction statements with contractor records before filing is worth the time.

Practical steps: making the EPS work correctly

Collect CIS deduction statements promptly

Each contractor who deducts CIS must provide a written statement at the time of payment showing the gross amount, the materials element, the CIS deduction and the tax period. Without the statement there is no documented basis for the EPS offset. Request it in writing if a contractor is slow and follow up before the 19th filing deadline.

Total the deductions by tax month

Tax months run from the 6th to the 5th. All contractor deductions falling within the same tax month are added together. Attribution uses payment date, not invoice date: a payment on 3 August sits in the month ending 5 August; a payment on 8 August sits in the following month.

Enter the figure in the CIS suffered field

Most cloud payroll packages include an EPS CIS deductions suffered field. It must be populated manually each month. The software does not pull the figure from your invoicing system. Leaving it blank means the EPS reports no offset and the full PAYE falls due.

File the EPS by the 19th and pay the balance by the 22nd

The EPS must reach HMRC by midnight on the 19th of the following month. Electronic payment of the remaining balance is due by the 22nd. A late EPS triggers a full PAYE demand. Recovery needs a correcting EPS and a call to the employer helpline, adding time and a potential late-payment notice. Treat the 19th as a hard deadline.

Retain deduction statements for three years

HMRC can request the underlying CIS statements for any period in the last three years during a compliance check. Without them, the EPS offset becomes unsupported and HMRC can charge for underpaid PAYE. File statements by contractor and tax month as they arrive.

EPS route versus sole-trader Self Assessment: a direct comparison

The difference in timing between the two routes is not an administrative detail. For a business with meaningful CIS deductions it is a working-capital question that affects the ability to fund payroll, materials and the forward pipeline.

Sole trader (Self Assessment) Limited company (EPS)
Recovery mechanism Self Assessment return, filed by 31 January after the tax year EPS offset against PAYE, filed monthly by 19th
When money comes back February following the tax year at the earliest Each monthly PAYE cycle, starting the month after the deduction
Typical wait from first deduction Up to around 22 months on the earliest deductions if filed at the deadline Approximately 30 days per month's deduction
How excess is treated Refund via Self Assessment; HMRC online repayment typically 5 to 10 working days after SA processed Offset against CT liability, or cash refund within 25 working days of final EPS and CT600
Cash locked with HMRC at any point during the year Accumulates month by month; full year's deductions potentially locked until February Largely absorbed each month; only unabsorbed surplus carried at year end
Administrative requirement One Self Assessment return per year Monthly EPS submission; deduction statements each pay period

On the figures in the worked example (£8,000 a month gross CIS labour, 20% rate), a sole trader accumulates £19,200 locked at HMRC over a full year before the January Self Assessment deadline releases any of it. The same limited company, using the EPS correctly, recovers most of that credit each month against its PAYE bill.

The limited-company structure brings additional costs: CT filing, dividend extraction (2026/27 rates: 10.75% basic, 35.75% higher, 39.35% additional), employer NIC at 15% above £5,000, and accountancy fees typically £150 to £250 a month for a company with full CIS compliance. The structure decision should weigh all of those, not just the EPS timing benefit. Our guide to CIS sole trader versus limited company works through the full comparison.

The alternative: Gross Payment Status

Both routes above involve recovering money that was deducted in the first place. A company with Gross Payment Status (GPS) is paid at 0%, so there is nothing to reclaim. GPS requires passing a turnover test (£30,000 per director or £100,000 total net CIS turnover for a limited company), a business test and a 12-month compliance test.

From 6 April 2026, Finance Act 2026 (c.11, s.220) allows HMRC to revoke GPS immediately where a contractor knew or should have known about fraud in the supply chain. Under the inserted provisions (ss.62A and 62B of Finance Act 2004), a company faces a charge of 20% of the relevant payment, with a further penalty under s.72A of up to 30% of that s.62A or s.62B amount. Where the company does not pay the s.72A penalty, s.72B allows HMRC to issue a decision notice to a company officer requiring that officer personally to pay a specified portion of it, up to 100% of the company's s.72A penalty. The reapplication ban differs by case type: one year following a s.62A determination and five years following a s.62B determination. For a company on £500,000 turnover, losing GPS costs roughly £100,000 a year. The full qualification tests and anti-fraud requirements are covered in our guide to CIS Gross Payment Status.

Estimating the benefit for your company

To sense-check the monthly offset, take the labour element of your typical CIS invoices and apply the rate (0% GPS, 20% registered, 30% unregistered), then compare the result to your monthly PAYE and NIC bill. Our CIS deduction calculator works out the deduction on any invoice, splitting labour and materials and applying the correct rate. Our CIS Self Assessment calculator estimates the year-end position for sole traders, useful as a comparison when weighing incorporation.

If your limited company is having CIS deductions made and the EPS offset is not in use, or there is a mismatch between what has been claimed and what contractors reported on their CIS300 returns, resolving that before HMRC's annual reconciliation is worthwhile. Our CIS compliance service covers the in-year EPS process and the year-end excess-credit claim as part of an ongoing advisory relationship, not a one-off recovery exercise.