A colleague from your Dubai office flies into Manchester for four days of client meetings. Nobody in payroll hears about it. On HMRC's reading, a UK payroll obligation started the moment she performed employment duties here, and it will sit unresolved on your file until someone finds it.
TL;DR: UK PAYE can apply from day one when an overseas employee works here. Relief comes from an Appendix 4 or Appendix 8 agreement with HMRC, not automatically from a tax treaty. Agreements must be in place by 5 April to cover that tax year, with the annual report due by 31 May.
HMRC published Guidelines for Compliance 19 on 13 August 2026, covering employers with overseas staff working here for short periods. It introduces no new law. It does put HMRC's expectations in one place for the first time, with a candid list of the mistakes it keeps finding.
What Counts as a Short-Term Business Visitor?
Someone who normally works overseas but comes to the UK briefly to carry out employment duties, usually employed by an overseas parent, subsidiary or group company. They arrive for meetings, training, a project handover or a board session.
The label has nothing to do with immigration status. What matters to HMRC is whether duties were performed on UK soil, and whether a UK entity is the real beneficiary of that work.
In our experience the people most often missed are senior. Group finance directors, regional heads and technical specialists move between offices frequently, rarely fill in a form when they do, and carry the largest daily earnings attached to each UK workday.
When Does UK PAYE Actually Start?
From day one of non-incidental duties for a UK entity, unless you already hold a short-term business visitor arrangement with HMRC and meet its conditions.
That's the point most employers get wrong. A treaty may well mean no UK tax is ultimately due, but it doesn't switch off the PAYE machinery by itself. The relaxation is administrative, and you agree it with HMRC in advance.
Incidental duties, checking email in a hotel or attending as a genuine observer, sit outside this. Running a workshop for the UK team does not. What we see most often is a visitor logged as "attending a meeting" whose calendar shows five days of delivery for the UK business. Because nobody reports it, the failure quietly repeats across several tax years, and HMRC can seek the tax, interest and a penalty on the whole period once it surfaces.
How Does an Appendix 4 Agreement Change Things?
An EP Appendix 4 arrangement lets you report qualifying visitors once a year instead of running real-time PAYE for each trip. It's the standard route for staff resident in a country with a UK double taxation treaty.
Four conditions have to hold: the employee is resident in a treaty country, they're working for a UK company or the UK branch of an overseas company, their earnings aren't ultimately borne by a UK entity, and they're expected in the UK for 183 days or fewer in the relevant 12-month period.
Reporting scales with time spent. GfC19 sets four bands: 1 to 60 days, 61 to 90, 91 to 150, and 151 to 183 days (HMRC, 2026). The top band needs an individual application, and the 91-plus bands need residence confirmation from the overseas tax authority.
One trap sits in the day count. For Appendix 4, a day means physical presence in the UK at any point in that day, weekends and holidays included. Appendix 8 counts only days when duties are performed. Teams that apply one definition to both understate their numbers.
What If There Is No Treaty, or the Employee Sits in an Overseas Branch?
Appendix 8 covers those cases. It's a PAYE special arrangement for visitors who can't claim treaty relief, including residents of non-treaty countries and employees of overseas branches of UK companies.
The limit is 60 UK workdays in the tax year. You calculate the total UK liability after year end and settle it in one payment by 31 May, rather than running payroll trip by trip (Grant Thornton, 2026).
Two exclusions catch people out. Appendix 8 can't be used where a UK National Insurance liability exists, and non-UK resident directors of UK companies can't be included at all. Directors are office holders, which puts them on a different footing from ordinary employees on both arrangements.
One concession is worth knowing. Where a visitor spends fewer than 60 days in the UK and that period isn't part of a longer stay, HMRC will accept treaty treatment even if UK costs are borne locally. It doesn't extend to overseas branches of UK companies.
Does Treaty Relief Cover National Insurance Too?
No. Treaty relief for income tax tells you nothing about National Insurance. GfC19 makes the point explicitly, and it's one of the more expensive assumptions we see.
Class 1 contributions are exempt for the first 52 contribution weeks where the worker isn't ordinarily resident or employed in Great Britain, their employment is mainly outside the UK, and their employer has a place of business outside the UK (Regulation 145(2), Social Security (Contributions) Regulations 2001, HMRC). The clock starts the contribution week after arrival.
For staff arriving from the UAE this matters more than most. The UK-UAE double taxation convention has applied to income tax since 6 April 2017, so the tax side is usually straightforward. There's no reciprocal social security agreement between the two, so the 52-week domestic rule is all you're relying on, and you need evidence to support it.
The Errors HMRC Says It Sees Most
Part 4 reads like a list of past enquiries: poor systems for identifying who's been in the UK, records too thin to support the position taken, and an assumption that PAYE doesn't apply to short visits. Also listed are miscounted workdays, missed cost recharges between group entities, treating an overseas branch as a separate entity, misreading the 60-day rule, and overlooking National Insurance altogether (HMRC, 2026).
HMRC expects PAYE records kept for at least three years from the end of the tax year. For visitors that means travel evidence, contracts, expenses, bonus and share award detail, and whatever supports your National Insurance position.
If it goes wrong, penalties under Schedule 24 Finance Act 2007 run from 0 to 30% of the lost tax for careless behaviour, 20 to 70% where the failure is deliberate, and 30 to 100% where it's deliberate and concealed (legislation.gov.uk).
Your Two Dates Before the Tax Year Ends
An arrangement only covers a tax year if HMRC has agreed it by 5 April of that year, so there's still room to get one running for 2026-27, with the annual report due 31 May 2027. You apply in writing to HMRC quoting your PAYE reference, and approval turns on evidence that you can actually track UK visits, so build the tracking first and apply second.
Start with the data. Ask travel, HR and the group finance team for every UK trip since 6 April, then compare that against expense claims and building access logs. The gap between those three sources is usually where the risk lives.
Historic exposure costs materially less to disclose unprompted than to have found for you. Cross-border employers should also read our guide to the UK's 4-year FIG regime for staff who end up staying, the payrolling benefits in kind changes due in April 2027, and our UAE WPS employer checklist if the same people sit on a UAE payroll. Our payroll and tax services cover both sides.
Frequently Asked Questions
Does a tax treaty mean I can ignore UK PAYE for a visiting employee?
No. A treaty may remove the final UK tax liability, but the PAYE obligation stands until HMRC agrees an Appendix 4 or Appendix 8 arrangement with you. Assuming otherwise is the most common failure in GfC19's error list.
How do I count UK days for a short-term business visitor?
It depends which arrangement you're using. Appendix 4 counts any day of physical presence in the UK, however brief, weekends and leave included. Appendix 8 counts only days on which duties are performed. The wrong definition understates your report.
Our staff come from the UAE. Do we owe UK National Insurance?
Usually not for the first 52 contribution weeks, provided the employee isn't ordinarily resident or employed in Great Britain and their employer has a place of business outside the UK. There's no UK-UAE social security agreement, so you're relying on the domestic exemption and need records to evidence it.
What if we have missed this for previous years?
Quantify the exposure first, then approach HMRC unprompted. Penalties for careless errors start at 0% on unprompted disclosure, against up to 30% if HMRC finds it first.
If your group moves people between the UK and overseas offices, get in touch and we'll review your visitor data against the Appendix 4 and Appendix 8 conditions, tell you whether an agreement is worth putting in place before 5 April, and flag any historic exposure while disclosure is still unprompted.