Rebecca Hartley — Financial Services & FinTech Lawyer in London

Her practice covers Real Time Information (RTI) compliance, setting up reporting frameworks to submit Full Payment Submissions (FPS) and Employer Payment Summaries (EPS) on or before every pay date to prevent automated HMRC penalties; National Insurance Contribution management, calculating Primary (employee) and Secondary (employer) Class 1 NIC liabilities, identifying applicable relief thresholds, and ensuring accurate treatment of directors' remuneration; workplace pension auto-enrolment with qualifying providers under The Pensions Regulator guidelines; and Benefits in Kind (BIK) reporting through Form P11D/P11D(b), including Payrolling Benefits in Kind (PBIK) and Class 1A NIC submissions.

Navigating non-traditional employment setups requires careful tax risk management. When Chinese enterprises use Employer of Record (EOR) or Professional Employer Organization (PEO) arrangements, Ms. Hartley reviews the underlying commercial contracts to verify that employer tax, statutory sick pay, statutory maternity pay, and auto-enrolment burdens are properly calculated and remitted to HMRC without creating hidden secondary tax liabilities for the client.

For entities engaging independent software engineers, consultants, or specialists via personal service companies (PSCs), Ms. Hartley conducts comprehensive Off-Payroll Working (IR35) assessments. Under the UK rules for medium and large-scale private sector client entities, the responsibility for determining employment tax status rests with the end-client. She delivers formal Status Determination Statements (SDSs), audits contractor working relationships, designs dispute resolution procedures for status appeals, and mitigates risks of retrospective Class 1 NIC and PAYE tax assessments from HMRC.

Cross-border employee movement between Chinese corporate parents and UK affiliates presents complex employment tax and social security challenges. Ms. Hartley structures mobile workforce tax strategies that eliminate double taxation while maintaining full statutory compliance in both jurisdictions.

She advises on National Insurance liability exemptions for short-term and long-term assignees sent from mainland China to the UK under statutory relief rules or bilateral arrangements, obtaining Certificate of Coverage documentation where applicable. She establishes Appendix 4 (Short-Term Business Visitors) agreements with HMRC to mitigate PAYE withholding requirements for China-based executives visiting UK subsidiaries for brief business trips, managing day-count tracking and business activity logs. She also structures Modified PAYE Schemes (Appendix 6) for senior Chinese expatriates, ensuring proper gross-up calculations, currency conversion protocols, and annual tax reconciliation returns.

In an environment of increased regulatory scrutiny, HMRC actively audits international businesses operating across borders. Ms. Hartley represents Chinese companies during HMRC Employer Compliance Reviews, wage and tax audits, and voluntary tax disclosures.

She conducts preemptive employment tax health checks, reviewing historical payroll data, worker classifications, expense reimbursement policies, and benefit treatments to identify liabilities before HMRC initiates an inquiry. Where discrepancies or inadvertent non-compliance are identified, Ms. Hartley prepares structured Unprompted Voluntary Disclosures, negotiating penalty mitigation and unpicking complex liability periods under HMRC's Senior Accounting Officer (SAO) and penalty frameworks.

Ms. Hartley works closely with corporate finance directors, tax leads, and HR heads. Service formats include upfront tax structuring opinions, IR35 audit packages, mobility policy design, and ongoing employment tax retainer advisory. Formal client onboarding requires standard regulatory identity checks and a clear written scope of work under Law Society and CIOT guidelines. Consultations are arranged via Lawson Gray Solicitors LLP.