Compliance deadline for Short-Term Business Visitors
While 31 May 2026 marks the end of Spring for meteorologists, for global mobility professionals, it marks the deadline for short-term business visitor compliance in the UK.
Short-term business visitors, or STBVs, are generally employees of an overseas parent, subsidiary, or other group company who come to work in the UK for a short period.
For STBVs visiting the UK, there is a strict payroll obligation from day one of non-incidental work for the UK entity unless the employer has agreed a short-term business visitor arrangement with HMRC and meets the conditions so that PAYE can be relaxed. An annual report must be made to HMRC by 31 May.
This year, one added complication is that we are seeing employers review individuals who have returned to the UK unexpectedly late in 2025/26 due to geopolitical events and may need careful assessment as to whether they do qualify as a short-term business visitor.
Who gets reported on a short-term business visitor arrangement?
HMRC allow employers to relax a PAYE obligation for short-term business visitors who are expected to be exempt from UK taxation under the terms of a double taxation agreement.
The more days an individual spends in the UK, the more information they must provide to HMRC.
Employers are expected to carefully check that they meet the conditions of the arrangement for each STBV to relax PAYE.
Key points to review
A day count on its own is not enough.
Employers should also look at whether:
- the UK entity is acting as the economic employer
- employment costs are ultimately borne in the UK, including through recharges or wider management
- UK workdays are being tracked accurately
- the conditions of the relevant double taxation agreement are met for that employee
- any changes in working patterns mean the historic approach should now be revisited.
Complexities
An Appendix 4 arrangement does not apply in every case. In particular, employers should take care with:
- employees visiting the UK from an overseas branch of a UK entity
- employees visiting from non-treaty countries.
In these cases, PAYE will generally be due. However, for STBVs with 60 or fewer UK workdays, an Appendix 8 arrangement may allow PAYE to be dealt with under an annual submission by 31 May.
If an employer has any non-resident directors who perform board duties in the UK, they will generally fall outside the normal STBV arrangements, and PAYE may need to be operated. The expense and social security position should also be reviewed.
What should employers do now?
STBV compliance remains a key HMRC focus area. Non-compliance can leave employers exposed to interest and penalties on unpaid PAYE over many years.
As a practical next step, employers should ask:
- Do we have a UK short-term business visitor arrangement? If not, do we need one?
- Are we accurately tracking who is coming to the UK?
- Do we know where they have come from and what they are doing here?
- Have any geopolitical or operational changes altered the facts?
- Are we confident we have the right compliance position in place for 2025/26?
How can we help?
Our global mobility services team can help employers this spring understand their obligations regarding STBVs, assist with preparing and submitting a STBV report to HMRC, and also advise on tracking and monitoring employee presence in the UK.
If you would like to have a conversation to discuss this further, please do not hesitate to get in touch with your usual Crowe contact.
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