Annual filing deadlines for UK employment and mobility taxes

We are approaching the end of the current tax year, which means many employers have upcoming annual filing obligations with HMRC.

Navigating the landscape of employment tax, employment related securities and global mobility tax filings in the UK can be a complex and difficult task for employers. Ensuring compliance with these deadlines is crucial to avoid penalties and maintain smooth operations. 

We have outlined below some (but not all) of the key upcoming HMRC annual filing deadlines outside of normal payroll operation that employers might need to consider.

• Global Mobility key deadlines
• Employee benefits and termination payment reporting key deadlines
• Employment related securities reporting key deadlines

Global Mobility key deadlines

National Insurance Settlement Returns – Appendix 7A and 7B

Deadline following the end of the relevant tax year: 31 March

Who is this relevant to (subject to exact facts and circumstances)?

Employers with internationally mobile employees who remain liable to UK NICs and are included on an Appendix 6 Modified payroll.

Action required by deadline

Employers will be required to submit their National Insurance Settlement Returns to HMRC by 31 March following the end of the tax year. Employers must make sure they accurately calculate and report the National Insurance Contributions for their employees via these returns.

Short Term Business Visitors (STBV) arrangement – Appendix 4

Deadline following the end of the relevant tax year: 31 May

Who is this relevant to (subject to exact facts and circumstances)?

UK businesses with global operations who have overseas employees visiting for short periods from another country which has a double tax agreement with the UK containing a relevant employment income or dependant services article.

Action required by deadline

Businesses who have an STBV arrangement with HMRC are required to report to HMRC the details of short-term business visitors to the UK who might ultimately be protected from UK tax, under their “Appendix 4” agreement. It is important to note that there is still an obligation to review data and submit a report to HMRC, even if this is a nil report. 

Businesses who do not have such an agreement with HMRC, but who do have such business visitors, should consider applying for one to help manage the potential PAYE income tax requirements which might arise from the first day of such a short-term business visitor’s trip to the UK.

PAYE Special Arrangement for STBVs – Appendix 8

Deadline following the end of the relevant tax year: 31 May

Who is this relevant to (subject to exact facts and circumstances)?

UK businesses with global operations who have overseas employees visiting for short periods from another country with no double taxation agreement with the UK, or visitors who are employed by an overseas branch of the UK company. 

Action required by deadline

A UK employer with such an agreement must pay and report the income tax due in respect of the PAYE income arising for such a short-term business visitor to HMRC by the deadline. This is due annually, as the agreement results in an annual PAYE scheme being set up.

Businesses who do not have such an agreement with HMRC, but who do have such business visitors, should consider applying for one.

Net of foreign tax credit relief – Appendix 5

Deadline following the end of the relevant tax year: 31 May (to reflect the deadline for issuing form P60)

Who is this relevant to (subject to exact facts and circumstances)?

UK employers who have employees working overseas and who may want to deduct foreign tax from their payments while continuing to operate and deduct UK PAYE. The arrangement allows provisional double taxation relief via payroll for employees who pay tax in the UK and overseas on the same earnings.

Action required by deadline

Employers with such an arrangement with HMRC must report the details of such employees to HMRC together with details of the foreign tax paid and the relief claimed.

Employee benefits and termination payment reporting key deadlines

PAYE Settlement Agreement (PSA)

Deadline following the end of the relevant tax year: 5 July, 31 July and 22 October

Who is this relevant to (subject to exact facts and circumstances)?

Employers who provide minor, irregular or impracticable benefits to employees which are taxable and liable to NIC.

Action required by deadline

Employers who want to settle the tax and National Insurance on minor, irregular, or impracticable benefits. The agreement (or updated agreement) must be in place with HMRC before 6 July following the end of the tax year it relates to, with the filing required by 31 July and payment due by 22 October (19 October if paying by post). Please note, the 31 July filing deadline is non-statutory but is normally stated on the agreement.

In the absence of a PSA such benefits must be reported to HMRC on annual forms P11D and/or via the payroll as required.

P11Ds & P11D (b)

Deadline following the end of the relevant tax year: 6 July and 22 July

Who is this relevant to (subject to exact facts and circumstances)?

Employers who provide taxable benefits/certain expenses to employees and directors.

Action required by deadline

These forms report taxable benefits and certain expenses provided to employees. The deadline for submission is 6 July. The payment of Class 1A National Insurance Contributions (NICs) showing as due on the form P11D(b) should be paid by 22 July if paid electronically (19 July if paid by post). 

For any individuals included on an Appendix 6 modified payroll who receive benefits in kind, the filing deadline for the P11Ds is 31 January following the end of the tax year, however if any NIC is due, this still needs to be paid by either 19 or 22 July.

Note that where a benefit is payrolled, the value must still currently be reported on a form P11D(b) to enable the Class 1A NIC to be paid to HMRC. Note also that most benefits will need to be payrolled mandatorily for both tax and NIC purposes from 6 April 2026.

Termination package reporting

Deadline following the end of the relevant tax year: 6 July

Who is this relevant to (subject to exact facts and circumstances)?

Employers who have made a termination package to an employee/former employee or director/former director which consists of cash and non-cash elements, and where the total value exceeds £30,000.

Action required by deadline

A report must be submitted to HMRC including the details of the employee, the amounts of the payments and value of the non-cash benefits, and the tax and NIC treatment applied. A copy must also be provided to the employee by the same deadline.

Employment related securities reporting key deadlines

Employment Related Securities (ERS) annual returns

Deadline following the end of the relevant tax year: 6 July

Who is this relevant to (subject to exact facts and circumstances)?

Returns are required to report most transactions in shares, options, or other forms of security (eg loan notes, carried interest) involving employees and directors (including non-executive directors and UK participants of overseas plans). 

Action required by deadline

Employers are required to submit an annual ERS return to HMRC by 6 July. This should report all share-related transactions during the UK tax year.

This includes HMRC tax advantaged share plans such as Enterprise Management Incentive (EMI), Company Share Option Plan (CSOP), ShareSave/Save As You Earn, and Share Incentive Plan, as well as non-tax advantaged arrangements.

Note that reportable events can and often do extend to transactions outside of formal share plans. 

Enterprise Management Incentive (EMI) grant notifications

Deadline following the end of the relevant tax year: 6 July

Who is this relevant to (subject to exact facts and circumstances)?

EMI options granted on or after 6 April 2024.

Action required by deadline

For EMI options granted during the 2024/25 tax year, grants must be notified to HMRC by 6 July 2025. 

Options granted prior to 6 April 2024 should have been reported within 92 days of grant.

Failure to notify on tie can result in a loss of EMI tax reliefs.

If you require assistance or have any questions, please do not hesitate to get in touch with Lee Knight, Kerrie Willis or your normal 91探花contact.

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