The full mandation of the PBIKs regime should prove to be a welcome simplification for both employers and HMRC in due course. A thorough consultation process will be required, however, to help ensure that complexities around the calculation of certain benefits-in-kind are addressed, prior to going live in April 2026.
HMRC has confirmed that it intends to engage with stakeholders to inform design and delivery decisions and the development of draft legislation later in 2024. HMRC will also work with interested parties to produce guidance, which will be made available in advance of April 2026.
In particular, consideration will need to be given to those benefits which are currently deemed too complex to be included in the voluntary PBIKs regime. This may entail giving further thought to a process for calculating the taxable benefit on interest-free loans on a “best estimate” basis, with a true-up following the end of the tax year.
For employer-provided accommodation, this may be a suitable moment to revisit some of the reforms considered in the 2016 call for evidence, which concluded without any changes to the existing means of taxing such benefits.
In the meantime, the voluntary PBIKs regime remains open to all employers, so if there are businesses that wish to get ahead of the curve, registration for voluntary payrolling during the 2024/25 tax year must be carried out before 6 April 2024.