However, the Revenue is considering a change that would mean the only route for an appeal would be at the High Court – which could cost up to £50,000.
The Revenue is currently consulting the industry on how best to overhaul the scheme in April 2005.
The proposed changes provide a stiff challenge for all contractors
Alan Nolan, director, KPMG
KPMG director Alan Nolan, who sits on the CIS consulting panel, warned that the move would prove costly. He said: "The Inland Revenue is looking to remove the General Commissioners' powers to overturn its decision to refuse an application for a CIS certificate."
Nolan said this would leave subcontractors facing legal bills of up to £50,000 for appealing to the High Court.
He added: "The proposed changes provide a stiff challenge for all contractors. It is the Inland Revenue's intention to make the compliance test far more strict under the new regime."
Nolan also warned that the scheme would require new IT systems, staff training, policy documents and self-employment reviews in order to comply, which he says will involve more detailed reporting to the Revenue.