On 14 May 2018 HMRC issued a consultation on the tax and administrative treatment of short term business visitors from overseas branches. The consultation closes 6 August 2018:
This consultation is a welcome move, as HMRC acknowledges the burden faced by companies managing the tax/payroll administration required to be compliant for business travellers from overseas branches and the current disparity in treatment to visitors from overseas subsidiaries.
Two proposals have been included within the consultation. It is not immediately clear whether the the options are both 'on the table' or are mutually exclusive, although the language used in the consultation questions would suggest the latter. They are as follows:
Extend the Annual Payment Scheme to 60 workdays
PwC's initial view: the extension of the special arrangement from 30 to 60 workdays would ease the burden on companies who effectively have to have two processes to account for those under 30 and over 30 workdays. However, while extending the days would be welcome, it does not fundamentally address the disparity in treatment for branch visitors as such employees would still incur an income tax liability. We also recognise that, although it is certainly a better alternative than a strict application of PAYE many clients struggle with the timeframes and administrative burden associated with reporting under the Annual Payment Scheme. As the consultation suggests that there would be no cost to the Exchequer of making this change, we would encourage consideration of making this change regardless of the status of branches.
