In their March bulletin issued to agents, HMRC confirmed that, along with the expected changes to the taxation of non-domiciled individuals, the process for applying for a Section 690 direction to operate PAYE on only a proportion of a globally mobile employee’s income is changing.
In more pressing news, HMRC has confirmed that all existing Section 690 directions issued before 6 April 2025 will cease to have effect from this date. This means that any current directions effective for the 2025/26 and later tax years will need to be reapplied for:
“The new process will allow employers and their agents to send HMRC a notification specifying a proportion of income paid to a globally mobile or treaty non-resident employee which will be treated as not being PAYE income.
Employers and agents can notify HMRC using a new online notification form, available from 6 April, allowing them to operate PAYE on the reduced amount of income as soon as HMRC acknowledges receipt of the notification. This should be immediate. Any HMRC directions issued before 6 April 2025 will cease to have effect from that date. This means that if employers wish to operate PAYE on a reduced amount of an eligible employee’s income for the 2025/26 tax year, they will need to submit a new notification.”
While it is good news that the new directions can be operated immediately, action must be taken in all cases where you have employees with a Section 690 direction that you wish to operate for the 2025/26 UK tax year.
All employers should therefore urgently review their existing population of globally mobile employees where a Section 690 is in place.
This may include:
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Outbound employees with ongoing taxable UK workdays
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Inbound employees who are non-resident (either under the SRT or a double tax treaty) or eligible for Overseas Workday Relief
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Short-term business visitors who do not meet the eligibility criteria to be included on the STBV report
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Non-resident directors with UK board duties
While we hope the new online form will make the process as straightforward as possible, it will not be released until 6 April. We recommend consulting with your advisor to ensure the correct action is taken for any existing Section 690 directions to be valid for the 2025/26 tax year, ahead of your April payroll cutoff date.
Please get in touch if TAP can assist.