National Insurance Contribution questions

16 September 2020

The CIPP sits on HMRC’s Expat Forum, to ensure that the Policy and Research team can keep payroll professionals informed about any changes to global payroll, and similarly so that we can provide feedback to HMRC on the same topic.

The Expat Forum is currently working to resolve outstanding National Insurance (NI) Contributions issues, and there are currently two key points relating to:

•    S62 payments and Internationally Mobile Employees – ‘apportionment’, or an ‘all or nothing’ approach
•    The overarching practical operation of NI contributions on S62 payments and Employment-Related Securities (ERS) chargeable events – to look at double charges and the interaction with overseas jurisdictions.

HMRC is asking for feedback, by no later than close of play on Friday 18 September 2020, on a couple of questions that relate to the key points.

If members have any feedback, which the Policy team would be really grateful for, then they should send it, via email, to [email protected].

The feedback requested relates to evidence and / or examples of how S62 payments and ERS are being handled in practice. Specifically, information is required in relation to the below, as feedback has suggested that HMRC has taken an inconsistent approach to these cases.

•    The number of employers utilising an ‘all or nothing’ approach against those who are operating an ‘apportionment’ method for S62 payments, and the number of employees who are impacted by this
•    Any interactions with HMRC in respect of these approaches, giving examples of inconsistency, where applicable
•    The number of employers who are affected by the issue of double charges on both types of payment, and the extent of this

HMRC would also like feedback on the issue of the extent of the changes required to implement the ‘apportionment’ approach for S62 payments. Expat forum members highlighted their concerns relating to the changes required to systems and processes to implement this approach, so HMRC is asking for the following details:

•    The number of employers who will require changes to be made to both their systems and processes, and the extent of those changes
•    The required lead-times for implementation of the changes to systems and processes

As always, the team would like to thank you in advance for any feedback you may provide.

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