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Purpose, scope and background (part 1)

Published 13 August 2026

Purpose and scope

These guidelines provide important information on the Income Tax and National Insurance contributions treatment for short-term business visitors to the UK.

The guidelines are primarily intended for:

• UK employers who have overseas workers performing duties in the UK on a short-term basis
• overseas employees who perform duties in the UK on a short-term basis

The guidelines will also be helpful to agents and professional bodies that represent and advise on these situations.

We have developed them to help employers and employees:

• comply with their UK tax obligations such as PAYE, Income Tax and National Insurance contributions
• get their tax compliance correct first time
• understand what HMRC considers good practice
• retain the correct information, documents and records

Following these guidelines will help reduce the risk of errors and the potential for interest and penalty charges.

How to use these guidelines

These guidelines do not represent a change in the law or HMRC policy. They are not intended to be used in isolation. You should read these guidelines alongside existing guidance on employment and workers coming from abroad in:

• PAYE manual PAYE81500 — PAYE operation: international employments: contents
• Double Taxation Relief manual DT1920 — Non-residents: UK income: employments
• Employment Income manual EIM40000 — The scope of the charge to tax on general earnings
• National Insurance manual NIM33550 — International — people going to or coming from abroad

The guidelines contain examples for illustrative purposes only. They are intended to help you understand HMRC’s view in various scenarios. However, each case is unique, and the examples should not be applied directly to your specific circumstances without considering the full context.

Description of terms 

Any reference to:

• ‘PAYE’ means the system which requires employers to collect Income Tax and National Insurance contributions from payments of employment income

• ‘UK earnings’ means earnings of the employment relating to duties physically performed in the UK

• ‘treaty relief’ means double taxation relief which can be claimed under the applicable double taxation treaty

• ‘ultimately borne’ refers to the entity which meets the cost of the employment remuneration after all recharging of any nature

• ‘short-term business visitor’ means an individual who normally works outside the UK but temporarily spends time performing employment duties in the UK — they can be:

  • ‘short-term assignees’ — employees on formal international assignments of up to 6 months

  • ‘business travellers’ — employees travelling to countries outside their home country, (for example on regular business trips or a one-off meeting)

  • ‘project workers’ — employees assigned to work on specific projects of variable lengths in countries outside their home country

  • ‘multi-state commuters’ — employees living in one country but travelling to and working in a second country on a regular basis (such as weekly)

Background

Ordinarily, any employment income which relates to duties performed in the UK will be subject to UK Income Tax. This means that an overseas employee who spends just 1 workday in the UK could be subject to UK Income Tax. However, where an employee only spends a very short period of time working in the UK for an overseas employer, treaty relief may be available to be claimed, so that there is no UK Income Tax liability.

A common misconception is that short-term business visitors working in the UK automatically have no UK Income Tax and National Insurance contribution liabilities, as the employee is expected to continue paying tax in their home country. Employers sometimes assume they therefore have no obligation to operate PAYE. This is not correct.

Even where treaty relief can be claimed by an employee, this does not prevent their taxable employment income from being PAYE income. This means employers with a UK presence (or other relevant UK entities) are usually required to operate PAYE on any employment income paid to a non-UK resident employee. This is the case even if there would be no UK Income Tax liability once treaty relief has been claimed.

However, there is no requirement to operate PAYE if both of the following conditions are met:

• the employer does not have a UK presence
• the employee is not working for a person who has a UK presence

To help employers manage their PAYE obligations in relation to short-term business visitors, HMRC offers 2 arrangements that can help reduce the administrative burden on employers and employees.

The arrangements are known as an EP appendix 4 arrangement and an EP appendix 8 arrangement.

Without these arrangements, employers may be required to operate PAYE on any payments of the employee’s UK earnings from the first day any UK duties are performed. The employee would then need to complete a UK Self Assessment return to claim any relief available under a double taxation treaty and to get a refund of UK Income Tax due. National Insurance contributions and obligations do not follow the same rules as Income Tax. EP appendix 4 does not cover National Insurance contributions and an individual liable to pay National Insurance contributions cannot be included under EP appendix 8.

Double taxation treaties also do not cover National Insurance contributions. Instead, the UK has social security agreements with other countries that generally ensure social security contributions are paid in only one country on the same earnings. Employers should check the terms of these agreements to determine whether their employee is liable to pay National Insurance contributions. Failure to do this could result in unexpected liabilities and penalties.

If there are no social security agreements between the UK and the other country, the UK domestic rules will apply.