On 16 October 2019, draft regulations to provide for real-time reporting of the new Class 1A

NIC liabilities from 6 April 2020 were published for consultation by HMRC. Under the National Insurance Contributions (Termination Awards and Sporting Testimonials) Act 2019, termination payments made from 6 April 2020 that exceed £30,000 and are taxable under ITEPA 2003 will give rise to an employer NIC charge.

The draft regulations provide that such NICs liabilities on cash or cash-equivalent payments should be paid and reported to HMRC as they arise (rather than under form P11D(b)). Termination awards that are benefits-in-kind should be paid and reported after the tax year end via form P11D(b).

The draft regulations can be viewed here.