RPSM13101590 - Technical Pages: International: Double taxation agreement relief: Modified PAYE arrangements for “tax equalised” employees

Modified PAYE arrangement for "tax equalised" employees

By prior agreement with HMRC an employer may operate a Modified PAYE arrangement for its "tax equalised" employees (see Appendix 6 of the Employment Procedures Manual which is available on the HMRC internet site). Should such an arrangement apply then relief under a double taxation agreement (DTA) for employer and employee contributions can be given in the PAYE calculation.

Under Modified PAYE the employer makes an estimated PAYE tax calculation for its "tax equalised" employees at the beginning of the tax year and, subject to review, pays PAYE tax on that basis during the year. The employer should exclude from the estimated PAYE calculation the contributions it will make on behalf of those employees to overseas pension schemes to which the provisions of a DTA apply. The employer may also exclude an amount for employees’ own contributions. This is on the understanding that the employer or advisers engaged by the employer will prepare the relevant tax returns of its “tax equalised” employees in accordance with IR212.

Glossary ( RPSM20000000)