½Û×ÓÊÓƵ

Although a primary contribution liability will arise in respect of earnings paid by an overseas employer to an employee who is gainfully employed in the UK, subject to the comments below about EU social security regulations and continuing social security agreements post-Brexit, the employer itself will not be liable to pay secondary contributions on those earnings provided that, at the time such contributions would become payable, it is neither resident nor present in the UK, nor has a place of business here¹. A 'place of business' is not defined in the legislation but it is accepted by HMRC that, where the employer in question is a foreign corporation, the fact that it might have a UK subsidiary, or might itself be the subsidiary of a UK parent company, gives it neither a place of business nor a presence here. It might be thought, therefore, that where a foreign corporation does have a subsidiary/parent company in the UK, staff who are to work for the group in the UK should (particularly if they are to be highly-paid)