In August 2015, the British government announced a change to the rules for resident foreign nationals.



  • 0 harmful
  • 0 neutral
  • 1 liberalising
Inception date: 19 Aug 2015 | Removal date: open ended

Post-migration treatment

 On 19 August 2015, according to the consultancy Deloitte, HM Revenue & Customs (henceforth: HRMC) published a new special Pay-As-You-Earn (PAYE) arrangement for short-term business visitors working in the UK no more than 30 days in a year. The arrangement concerns nationals of those countries with which the United Kingdom has not signed a Double Taxation Treaty.
According to Deloitte, "Despite its limitations, the new agreement is likely to be viewed as a welcome addition to the existing suite of PAYE agreements available in connection with internationally mobile employees. The agreement should help employers manage their PAYE obligations in relation to STBVs 'i.e. short-term business visitors' who work in the UK for the benefit of a UK employer for no more than 30 days per tax year but cannot claim exemption from UK tax under the provisions of a relevant DTT 'i.e. Double Tax Treaty'. The STBVs to whom the agreement is expected to apply will include:

  • STBVs who are employed by the overseas branch of a UK company,
  • STBVs who are resident in a country with which the UK does not have a comprehensive DTT, and
  • STBVs who, while resident in a country with which the UK has a comprehensive DTT, do not meet the conditions to claim exemption from UK tax under the relevant DTT. This could, for example, include STBVs who cannot make use of the 60-day rule because, although they are present in the UK for fewer than 60 days in a single tax year, they are present for 60 days or more when linked periods are taken into account."

Despite the official document not being available on HMRC's website, the information provided by Deloitte (together with its assessment) proves credible, given that the consultancy has "discussed with HRMC" initial drafts to this arrangement and has been providing extensive coverage of the steps during its implementation (cf. Sources).