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PAYE withholding should be operated from day one on employees visiting the UK who are working for a UK company (note the term 'working for' is not specified within the legislation, though generally any visits that involve interaction with the UK business could be considered by HMRC to fall within its interpretation of the wording).

This withholding requirement can be relaxed by entering into a short term business visitor (STBV) agreement with HMRC (aka an 'EP Appendix 4' agreement) that allows employers to effectively anticipate an exemption from tax on the employee's UK earnings by virtue of an appropriate double tax treaty.

Up until tax year 2012/13, HMRC accepted that employers could apply the treaty relief where applicable, provided the days spent in the UK were adequately tracked and data was held to support a treaty claim, even where an STBV agreement is not held.

From tax year 2013/14 onwards however, HMRC stated that this practice no longer applies and that for the PAYE relaxation to stand, employers