A&M Tax Advisor Update

Social Security Considerations in the Event of a No Deal – HMRC Special Employer’s Bulletin

Louise Jenkins, Senior Director

louise.jenkins@alvarezandmarsal.com

April 5, 2019 / Europe

On the 4th April 2019, HM Revenue & Customs (HMRC) published a special employer bulletin relating to key social security considerations in the event of no deal exit from the E.U.

HMRC has confirmed our initial fears that double social security costs could potentially arise. The alert mentions employee obligations, but in certain circumstances, there would be the potential for double employer costs too, plus the additional administration and compliance costs associated with such a position.

Whilst HMRC go on to say they are still working with E.U. members to try to reach a social security agreement even in the event of a no deal, they are placing the initial onus on employers to check with each competent authority in each location where you have UK employees working in the E.U., to ascertain the position. This is placing an enormous burden on U.K. business, and each E.U. authority, and in our view, is wholly unwelcome and not practically workable.

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Europe