HMRC Form P46 (Expat): Starter Checklist for Employees Arriving from Abroad
How inbound employees and UK employers use Form P46 (Expat) and the modern Starter Checklist to stop emergency 0T tax codes and claim expatriate concessions.
Short answer: Form P46 (Expat) was HMRC's dedicated notification form for employees arriving in the UK from overseas, now superseded by the employee Starter Checklist and Section 690 modified PAYE agreements. Inbound expats frequently suffer emergency tax deductions (tax code 0T on a month 1 basis) if their arrival status is incorrectly coded. Matthew advises employers and international assignees on correct PAYE onboarding, Overseas Workday Relief, and split-year arrival claims.
Key points
- Form P46 (Expat) has been superseded by the modern HMRC Starter Checklist with expatriate questions.
- Prevents the punitive 0T emergency tax code, which strips your Personal Allowance and taxes first-month earnings at up to 45%.
- Inbound expats on secondment can use Section 690 directions to operate PAYE on UK workdays only.
- Qualifying arrivals can combine proper onboarding with Overseas Workday Relief (OWR) under the 4-year FIG regime.
- Split-year tax residence (Cases 4 to 8) must still be formally claimed on annual Self Assessment form SA109.
Why inbound employees get hit with emergency 0T tax codes
Few things are more disheartening than relocating to the UK for a prestigious role only to discover your first monthly payslip has been severely eroded by emergency tax deductions.
Because an arriving international employee does not have a UK P45 form from a previous domestic employer, UK payroll software defaults automatically to emergency code 0T M1. Under 0T on a non-cumulative (Month 1) basis, you receive zero tax-free Personal Allowance (£12,570), and earnings are taxed immediately from pound one. For international assignees and executives, this often means seeing 40% to 45% deducted at source from their very first pay run.
Starter Checklist vs legacy Form P46 (Expat)
Historically, employers completed paper Form P46 (Expat) to notify HMRC when an overseas worker was seconded or recruited to the UK for more than six months.
Today, this information is captured digitally through HMRC's Real Time Information (RTI) payroll system via the employee Starter Checklist. The checklist verifies whether you have worked in the UK during the current tax year, whether you remain employed by an overseas entity, and whether you are exempt from UK National Insurance under reciprocal social security treaties (via a Certificate of Coverage or A1 certificate).
Completing this accurately before payroll runs ensures your employer applies code 1257L M1 rather than 0T, instantly protecting your monthly tax-free allowance.
Section 690 modified PAYE and Overseas Workday Relief
For globally mobile staff who spend part of their working time performing duties outside the UK, full UK PAYE deductions at source may be legally excessive.
Under Section 690 of ITEPA 2003, your employer can apply to HMRC for a modified PAYE direction. This authorises payroll to deduct PAYE only on the estimated percentage of work physically carried out in the UK (for example, 60%), leaving the remaining 40% untaxed at source to reflect overseas working days.
Under the 4-year Foreign Income and Gains (FIG) regime from April 2025, qualifying employees who were non-UK resident for 10 consecutive years can claim statutory relief on foreign employment earnings. Matthew reviews overseas employment contracts and helps executives and employers coordinate Section 690 agreements and year-end SA109 filings.
Ensure your expat arrival is tax-optimised...
Matthew advises inbound executives, contractors, and international assignees on correct PAYE coding, Section 690 directions, and split-year arrival claims.
Archival reference: historic Form P46 (Expat) PDF download
For HR professionals, payroll advisers, and international assignees reviewing historic secondment records, you can download an archival copy of HMRC Form P46 (Expat) below.
Please note: Modern arrivals must be processed through RTI payroll and the current GOV.UK Starter Checklist. Form P46 (Expat) is provided strictly for historic and reference purposes.
Download historic Form P46 (Expat) (PDF)...
Looking for historic expatriate payroll statements or assignment questions? You can download the 4-page reference PDF below. Matthew reviews your UK tax code and prepares your arrival split-year return.
Frequently asked questions
What is an emergency 0T tax code and why was it applied to my UK salary?
If an inbound employee starts work without a P45 from a previous UK employer, payroll systems default to code 0T on a non-cumulative (Month 1) basis. This gives you zero Personal Allowance, taxing your entire first month's earnings at 20%, 40%, and 45% bands without any tax-free threshold. Completing the Starter Checklist correctly ensures the standard tax code (1257L) is applied.
Can an employer operate PAYE only on UK workdays for an expat employee?
Yes. Under Section 690 of the Income Tax (Earnings and Pensions) Act 2003, employers can apply to HMRC for a formal direction allowing PAYE to be operated only on estimated UK workdays, shielding overseas duties from UK payroll withholding.
How do I claim a refund for emergency PAYE deductions after arriving in the UK?
If you suffered excess PAYE deductions during your arrival year, the refund is claimed through your annual Self Assessment tax return. By claiming split-year residence on Form SA109, HMRC recalculates your tax based strictly on your UK arrival date and repays the overwithheld tax directly to your bank account.
Is Form P46 (Expat) still accepted by HMRC?
No. HMRC abolished standalone paper P46 forms in favour of Real Time Information (RTI) digital payroll submissions and the online Starter Checklist. However, reviewing the historic P46 (Expat) fields remains useful for verifying assignment dates and social security agreements.
Written and reviewed by Matthew S Manderson CTA ATT AMIT
Chartered Tax Adviser (CTA), Association of Taxation Technicians (ATT), Association of Malta International Taxation (AMIT). General guidance only; tax treatment depends on individual facts.