The PAYE special arrangement covering short term business visitors was introduced in 2015/16 following a review by the Office of Tax Simplification. It allows a simplified form of payroll reporting to be operated in respect of short term business visitors from overseas who are unable to meet the criteria for exemption under a double tax treaty, provided that certain conditions are met.
Following a consultation over the summer on the tax and administrative treatment of short term business visitors, the government has decided to extend the current PAYE special arrangement in two ways. First, the number of UK workdays a short term business visitor may have that are subject to the special arrangement will be doubled from 30 to 60 days per tax year. Second, the deadline for submission of the reporting required by the employer will be extended from 19 April following the end of the tax year to 31 May.
The measure will affect employers who have business visitors to the UK, for whom no treaty exemption applies. The categories of business visitors where no treaty exemption applies will typically include business visitors from non-treaty countries and those employed via overseas branches of UK companies.
The measure will take affect from 6 April 2020.
We welcome the extension of the PAYE special arrangement, and the extension of the reporting deadline in particular as this in practice was the greatest constraint on employers’ ability to use it. A more generous timeframe would have been appreciated by some taxpayers, especially bearing in mind that pay data has to be gathered internationally to complete the required reporting.
The consultation had also considered the possibility of a tax exemption, equivalent to that in tax treaties, for UK employers with a branch rather than subsidiary based group structure. This appears to have been abandoned, which will be disappointing to employers who have short term business visitors from foreign branches of UK employing companies.
Global Employer Services Policy Lead