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Sections 688 ITEPA 2003

An individual works for a UK client. »Ê¹ÚÌåÓýapp individual is hired to work for the client via a UK agency. »Ê¹ÚÌåÓýapp worker is paid by an offshore intermediary of the client. Payment is made in readily convertible assets.

Is PAYE due on the payment by the overseas intermediary?

»Ê¹ÚÌåÓýapp overseas intermediary making the payment is outside the PAYE regulations but the remuneration arises under an agency agreement (see the Employment Status Manual, ESM2000).

A payment of readily convertible assets in these circumstances is treated as a payment by the UK agency (under sections 688(1) and 696 ITEPA 2003) for the purposes of Part 11 ITEPA 2003. So the agency is required to operate PAYE.