Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must be withheld and accounted for to HMRC by employers (and other payers) in relation to certain payments of: • employment income • pension income, and • social security income (together, PAYE income) For more information, see Practice Note: Scope of the PAYE system. PAYE income includes cash payments made to employees or directors (eg salaries, bonuses and termination payments). Non-cash payments are generally excluded from the operation of PAYE but a key exception to this is payments in the form of (or deemed to be in the form of) readily convertible assets. In the context of employment-related securities, whether or not PAYE obligations arise is dependent largely, but not entirely, on the employment-related securities in question being readily convertible assets. For full details on the meaning of readily convertible assets, see Practice Note: PAYE—readily convertible assets, intermediaries and jurisdictional scope. An important rule in this context is that all securities

Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must be withheld and accounted for to HMRC by employers (and other payers) in relation to certain payments of: • employment income • pension income, and • social security income (together, PAYE income) See Practice Note: Scope of the PAYE system. PAYE income includes cash payments made to employees or directors (eg salaries, bonuses and termination payments). Non-cash payments are generally excluded from the operation of PAYE but a key exception to this is payments in the form of (or deemed to be in the form of) readily convertible assets. Whether or not PAYE obligations arise upon acquisition of securities on exercise of an employment-related securities option depends on whether the securities in question are readily convertible assets. For full details on the meaning of readily convertible assets, see Practice Note: PAYE—readily convertible assets, intermediaries and jurisdictional scope. An important rule in this context is that all securities are deemed

HMRC has published guidance on new PAYE rules for labour supply chains that include umbrella companies which will apply from 6 April 2026.

A PAYE settlement agreement (PSA) is a voluntary arrangement which allows an employer to settle, in a single annual payment, the income tax and National Insurance contributions (NICs) liability of their employees on certain minor and irregular expenses and benefits. A PSA does not remove an employer’s requirements to operate PAYE on general earnings and appropriately report expenses and benefits. What can be included in a PSA? HMRC will agree to a PSA where amounts or benefits are made available to employees and the amounts or benefits are: • minor • irregular, or • impracticable to tax through the payroll, expenses or benefits systems Minor There is no definition of what qualifies as minor in monetary terms. HMRC provides a list for illustrative purposes: • incentive awards • reimbursement of late night taxi fares where the conditions for tax exemption are not satisfied • personal incidental expenses in excess of the daily tax-free limit • a present for an employee in hospital • staff entertainment, for example a ticket to a sporting event • use of a pool

Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must be withheld and accounted for to HMRC by employers (and other payers) in relation to certain payments of: • employment income • pension income, and • social security income (together, PAYE income) For further detail, see Practice Note: Scope of the PAYE system. PAYE income includes cash payments made to employees or directors (eg salaries, bonuses and termination payments). Non-cash payments are generally excluded from the operation of PAYE. A key exception to this is payments in the form of (or deemed to be in the form of) readily convertible assets, which are subject to PAYE. This Practice Note explains the definition of readily convertible assets, which is extremely wide. It includes assets (such as shares) which are tradeable on a recognised investment exchange (or certain specified commodities or stock exchanges). It also includes assets for which trading arrangements exist, such as: • alternative markets or exchanges, or • where

Parent Body Agreement: The contract between the NDA and the PBO.

Performance Based Incentives: Contractual figures which include performance-based incentives, key goals, objectives, targets or milestones agreed at the beginning of a financial year and of sufficient importance to warrant incentivisation (typically through a fee) to motivate the contractor to achieve.

Parent Body Organisation: The shareholder of the relevant SLC which is incentivised by the NDA to achieve "more decommissioning for less". The principal roles of the PBO are: (a) to hold shares in the SLC; (b) to second staff to the SLC; (c) to provide normal parent company functions; and (d) to improve the capability and performance of the SLC. The current PBOs are: (a) Cavendish Fluor Partnership (holding shares in Magnox Limited which now includes ex RSRL); (b) Cavendish Dounreay Partnership, a partnership comprising Cavendish Nuclear Services Limited, CH2M Hill and URSHoldings Limited (holding shares in Dounreay Site Restoration Limited); and (c) UK Nuclear Waste Management Limited (holding shares in LLW Repository Limited). (d) NDA - since 1 April 2016 Sellafield Limited has been a wholly owned subsidiary of NDA.

Practical completion

CASE HUB NOTE—appeal lodged before the General Court in Case T- 172/21 ARCHIVED—this archived case hub reflects the position at the date of the decision of 20 January 2021; it is no longer maintained. See further, timeline, commentary and related cases Case facts Outline European Commission Article 101 TFEU investigation into bilateral agreements concluded between Valve Corporation (the owner of a game distribution platform) and five video game publishers (Bandai Namco, Capcom, Focus Home, Koch Media and ZeniMax) to restrict parallel trade within EU Member States by preventing customers from buying cheaper games available outside of the customer’s location or country of residence (geo-blocking) Latest development On 20 January 2021, the Commission issued an infringement decision. Fines totalling €7.8m were imposed as follows:• Valve—€1.62m• Bandai Namco—€340,000 (including a 10% reduction for co-operation)• Capcom—€396,000 (including a 15% reduction for co-operation• Focus Home—€2.88m (including a 10% reduction for co-operation)• Koch Media—€977,000 (including a 10% reduction for co-operation)• ZeniMax—€1.66m (including a 10% reduction for co-operation) Parties Valve Corporation (Valve) is an US-based video game developer,

This Practice Note covers the automatic designation of the Secretary-General of the Permanent Court of Arbitration (PCA) as the appointing authority under the PCA Arbitration Rules 2012 (with Optional Protocols adopted in 2024) (the PCA Rules), how the tribunal is constituted under the PCA Rules and challenges to and replacements of arbitrators. The Practice Note also covers the exclusion of liability for the tribunal and persons appointed by it. Appointing authority PCA Rules, art 6(1) provides that the Secretary-General of the PCA shall serve as the ‘appointing authority’ under the PCA Rules. The primary role of the appointing authority is to assist with the process of constituting a suitable tribunal, by resolving problems that arise in constituting the tribunal, such as where parties cannot agree on a candidate for the sole or presiding arbitrator. As appointing authority, the PCA Secretary-General may appoint an arbitrator where there is no party agreement within a fixed period of time. The PCA Secretary-General maintains a list of PCA Members of the Court who are nominated by PCA Member

What is the PCA? The Permanent Court of Arbitration (PCA) is the world’s oldest intergovernmental organisation dedicated to facilitating the peaceful resolution of international disputes. Headquartered in The Hague, it was established by the 1899 Convention for the Pacific Settlement of International Disputes, which was signed at the conclusion of the first Hague Peace Conference in 1899. Originally focused on state-to-state dispute resolution, the PCA now administers and provides related services for disputes involving states, state-controlled entities, intergovernmental organisations and private parties. The PCA also maintains offices and hearing facilities outside The Hague, including in Buenos Aires, Mauritius, Singapore, Vienna and Ha Noi. In March 2026, the PCA Ha Noi Office inaugurated renovated hearing facilities at the House of Peace and published a Vietnamese translation of the PCA Arbitration Rules and Optional Protocols. For further detail, see: LNB News 27/03/2026 36. The PCA Arbitration Rules In December 2012, the PCA published its set of Arbitration Rules (the PCA Rules). The PCA Rules succeeded and replaced four sets of older PCA arbitration rules: