As the UK approaches another tax year end, many organisations are once again reviewing how they manage short term business visitors (STBVs). Given new styles of working, workforce mobility is more fluid than ever and global business travel has increased significantly. Employers must ensure they have the right processes in place to track visitor activity, meet payroll obligations and avoid unnecessary compliance risks.

Even a single working day in the UK can trigger income tax (Pay As You Earn - PAYE) and national insurance contributions (NIC) exposure. While the UK’s network of double taxation agreements (DTAs) can often relieve an individual from UK income tax, they do not remove the employer’s payroll and reporting responsibilities. A proactive approach is essential as HMRC continues to increase its focus on mobile workers and cross border risk areas.

STBVA requirements: what employers need to understand

For UK entities hosting short term visitors, an Appendix 4 short term business visitors agreement (STBVA) remains the most effective way to simplify PAYE compliance. An STBVA can be used for visitors arriving from countries with a suitable DTA – specifically, those containing an employment income or dependent services article.

When in place, an STBVA can:

• Remove the need to operate PAYE for qualifying visitors.
• Help businesses manage cash flow by avoiding unnecessary withholding where tax will ultimately be relieved.
• Eliminate the administrative burden of unnecessary UK tax returns for employees protected by a DTA.
• Provide assurance that the UK entity is compliant with HMRC expectations.

Employers with an active STBVA must file an annual report with HMRC by 31 May following the end of the tax year. The detail required depends on the number of UK workdays accrued by each individual.

Key considerations when assessing short term visitors

Beyond counting days, UK organisations need to evaluate a range of factors to correctly determine whether PAYE obligations arise.

• Economic employer analysis – determining whether the UK entity is the true host of the role or effectively benefits from the individual’s duties.
• Internal recharges – the nature of cross charge structures can influence whether treaty relief is available.
• The effectiveness of tracking procedures – robust systems for monitoring days, roles and activities are a key HMRC expectation and a requirement of an STBVA.

Where it is anticipated that an employee will spend between 151 and 183 days in the UK in the tax year, an individual application needs to be made to HMRC requesting confirmation that the employee can be included in the STBVA.

When a STBVA cannot be applied

While the STBVA is a valuable relief for many businesses, it is not universally applicable.

NIC liability

If a visitor is subject to UK NIC, they cannot be covered by an STBVA.

Individuals may be exempt, for example, if they hold a valid A1 certificate from an EEA country or Switzerland confirming they remain in their home social security system.

Visitors from non treaty countries

Employees coming from countries with no active DTA (such as Brazil until the new treaty comes into force) cannot be included.

For these individuals, employers could consider an Appendix 8 payroll, which allows for an annualised payroll process where the employee spends 60 UK workdays or fewer in the tax year, with tax due by 31 May after year end.

Overseas branch employees

Individuals employed by an overseas branch of a UK company fall outside the scope of the STBVA.

Non-UK resident directors

Directors who are not UK resident can’t be included in an STBVA. These cases carry additional complexity, and early advice is strongly recommended to manage both UK tax and NIC exposure.

Employment-related securities reporting

HMRC has confirmed that reporting relaxations available under the STBVA do not apply for employment-related securities (ERS) reporting (due by 6 July). Any employee receiving employment-related securities who works even one day in the UK during the grant to vest period may trigger a UK reporting obligation, increasing the compliance burden for international groups.

Employers will need detailed tracking of each visit, clarity on whether the UK entity is the host, and careful review of overseas share plans, as UK reportable events may differ from those in other jurisdictions. Tracking may also need to span multiple years to ensure accurate and complete reporting.

How we support employers with STBV compliance

Managing tax and NIC obligations for internationally mobile employees can be complex, especially as HMRC scrutiny increases and workforce mobility evolves. Our specialists can support you with:

• Completing and submitting STBVA or Appendix 8 applications.
• Designing or enhancing your STBV tracking system to meet HMRC expectations.
• Reviewing historic visitor activity to identify under reported cases.
• Assisting with voluntary disclosures where previous treatment may not have met UK requirements.
• Advising on the correct handling of non-resident directors and other high-risk categories.

If you would like to strengthen your compliance framework or sense check your current approach, please contact Ian Jones or Joanne Webber . We can also assist with technology solutions to support your controls.

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