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Regulatory Compliance for Employer-Sponsored Will Services: Legal and Tax Considerations

· 21 min

Executive Summary

Employer-sponsored will writing services occupy a uniquely complex compliance position, sitting at the intersection of employment tax law, consumer protection regulation, data protection requirements, and an unregulated legal services market. Will writing is not a reserved legal activity under the Legal Services Act 2007, meaning employers may procure services from providers operating outside any professional regulatory framework -- yet the benefit itself triggers obligations under ITEPA 2003, the Digital Markets, Competition and Consumers Act 2024, and UK GDPR.123 The convergence of mandatory payrolling of benefits in kind from April 2027, the inclusion of pension death benefits in inheritance tax from the same date, and the CMA's updated compliance guidance for will writing providers (January 2026) creates a compliance inflection point for HR and benefits teams.456 This article maps the multi-regulatory compliance architecture and provides an operational framework for structuring, procuring, and reporting employer will services within the current legislative environment.

1. The Compliance Landscape for Employer Will Services

Will writing is one of the few legal services that any person may provide in England and Wales without regulatory authorisation. The Legal Services Act 2007 defines six reserved legal activities: exercise of a right of audience, conduct of litigation, reserved instrument activities, probate activities, notarial activities, and the administration of oaths.1 Schedule 2 of the Act expressly excludes "wills or other testamentary instruments" from the definition of reserved instrument activities.1 The practical consequence is that employers may procure will writing services from both SRA-authorised firms and entirely unregulated providers, with no statutory requirement for the provider to hold professional qualifications, maintain professional indemnity insurance, or submit to regulatory oversight.

This regulatory absence does not, however, equate to a compliance vacuum. Employer-sponsored will services engage at least five distinct regulatory and legislative frameworks: HMRC's benefit in kind regime under ITEPA 2003; the CMA's consumer protection enforcement powers under the Digital Markets, Competition and Consumers Act 2024; the ICO's data protection framework under UK GDPR; the Equality Act 2010's non-discrimination requirements; and, where SRA-authorised firms are engaged, the SRA Standards and Regulations.2378

The SRA's guidance on employer provision of legal services clarifies that an employer providing legal services only to its own employees -- not to members of the public -- does not require SRA authorisation, though the SRA notes this remains "a matter to be determined by the Courts" based on specific circumstances.9 Where employers engage external providers, the regulatory obligations attach to the provider rather than the sponsoring employer, but reputational and contractual risk flows upstream.

Voluntary self-regulation exists through the Society of Will Writers, whose Code of Practice (version 2024.01) requires members to maintain professional indemnity insurance of at least GBP 2 million, comply with continuing professional development requirements, and adhere to complaints handling procedures.10 Membership, however, is not mandatory, and a substantial segment of the will writing market operates outside any self-regulatory framework. The House of Commons Library has documented periodic parliamentary calls for statutory regulation of will writers, none of which has resulted in legislation.10

The CMA concluded its investigation into will writing and other unregulated legal services on 30 January 2026, having launched in July 2023 following concerns about misleading advertising, unfair contract terms, pressure selling, and inadequate complaints handling.6 Seven providers were cautioned, and updated compliance guidance reflecting the DMCCA 2024 was published on the same date.6 Benefits compliance officers procuring will services should treat this updated guidance as a baseline for provider due diligence.

2. Tax Treatment: The Benefit in Kind Framework

2.1 Default Position Under ITEPA 2003

Employer-provided will writing services constitute a taxable benefit in kind under ITEPA 2003, Chapter 10, Part 3.2 The cash equivalent value of the benefit -- being the cost to the employer of providing or facilitating the service -- is assessable on the employee as employment income. The employer must report the benefit to HMRC, currently via P11D, and is liable for Class 1A National Insurance Contributions on the full cash equivalent value.11

The Class 1A NIC rate for 2025-26 is 15%, an increase from 13.8% in 2024-25.11 For a will writing service costing GBP 300 per employee, the employer's NIC liability is GBP 45 per participant. The employee bears income tax at their marginal rate on the GBP 300 benefit: GBP 60 for a basic-rate taxpayer (20%), GBP 120 for a higher-rate taxpayer (40%), or GBP 135 for an additional-rate taxpayer (45%).

The cost of providing will writing services to employees is deductible for corporation tax purposes where the expenditure satisfies the "wholly and exclusively" test under CTA 2009 s.54.12 Employee benefit costs are ordinarily treated as passing this test where they are commercially reasonable and relate to the employment relationship.

2.2 Trivial Benefit Exemption: Section 323A

The trivial benefit exemption under ITEPA 2003 s.323A may, in principle, apply to employer-provided will services where all four statutory conditions are met.13 Condition A requires that the benefit is not cash or a cash voucher. Condition B requires that the cost of providing the benefit does not exceed GBP 50. Condition C requires that the benefit is not provided under salary sacrifice or other contractual obligation. Condition D requires that the benefit is not provided in recognition of particular services performed by the employee. Directors and office holders of close companies are subject to an additional annual cap of GBP 300 in aggregate trivial benefits.13

In practice, the GBP 50 cost threshold renders this exemption inapplicable to most will writing arrangements. Market pricing for corporate will writing services typically ranges from GBP 100 to GBP 500 for a single will and GBP 200 to GBP 800 for mirror wills, with Lasting Power of Attorney add-ons increasing costs further. Only the most basic online will templates might fall within the GBP 50 threshold, and such services rarely constitute the substantive legal drafting that employer schemes are designed to provide.

2.3 Welfare Counselling Exemption: Not Available

HMRC guidance at EIM21845 addresses the welfare counselling exemption (SI 2000/2080, as amended by SI 2020/291, made under s.210 ITEPA 2003), which covers employer-provided counselling for stress, bereavement, debt problems, and workplace-related issues.14 The guidance explicitly states that the exemption does not extend to "advice on finance (other than advice on debt problems), advice on tax, advice on leisure or recreation, or legal advice."14 Will writing constitutes legal advice and falls squarely outside the welfare counselling exemption's scope. Benefits teams should not rely on characterising will services as part of a broader employee assistance or welfare programme to achieve exempt status.

2.4 PAYE Settlement Agreements: An Alternative Reporting Route

Employers may also consider PAYE Settlement Agreements (PSAs) under s.703 ITEPA 2003 as an alternative mechanism for settling the tax and NIC liability on will writing benefits.15 PSAs allow employers to make a single annual payment covering all tax and Class 1B NIC due on qualifying expenses and benefits that are "minor, irregular, or impracticable" to allocate to individual employees. Where will services are provided through periodic workplace events rather than individually allocated, a PSA may offer administrative simplification. However, PSAs require HMRC agreement, do not reduce the total tax charge, and must be applied for before the start of each tax year. Benefits teams should assess whether the episodic nature of their will services provision meets HMRC's qualifying criteria before pursuing this route.

2.5 Worked Example: Tax Cost of a GBP 300 Will Service

Consider an employer providing a GBP 300 will writing service as a benefit in kind to an employee earning GBP 55,000 (higher-rate taxpayer):

Employer costs:

  • Will service fee: GBP 300
  • Class 1A NIC (15%): GBP 45
  • Total employer cost: GBP 345
  • Corporation tax deduction (25%): GBP 86.25
  • Net employer cost after tax relief: GBP 258.75

Employee cost:

  • Income tax (40% on GBP 300 BiK): GBP 120
  • No employee NIC on BiK (Class 1A is employer-only)
  • Net employee cost: GBP 120

The total tax and NIC charge across employer and employee is GBP 165 on a GBP 300 benefit, illustrating why the tax treatment -- while not prohibitive -- warrants careful communication to employees enrolled in will writing schemes.

3. Salary Sacrifice and Optional Remuneration Arrangements

Provider marketing materials frequently promote salary sacrifice as a tax-efficient mechanism for delivering will writing services, suggesting employees benefit from income tax and NIC savings on the salary amount foregone. This characterisation is materially misleading in the context of the optional remuneration arrangements (OpRA) rules introduced by the Finance Act 2017.16

3.1 The OpRA Framework

Under ITEPA 2003 (as amended), where an employee gives up salary in exchange for a benefit in kind through an optional remuneration arrangement, the taxable value is the greater of the amount of salary foregone and the cash equivalent value under normal BiK rules.16 Only four categories of benefit are excluded from OpRA: employer pension contributions, cycle-to-work schemes, workplace nurseries, and legacy childcare vouchers.16 Will writing services are not an excluded exemption.

3.2 Practical Consequence

Where an employee sacrifices GBP 300 of salary for a will writing service costing GBP 300, the taxable value under OpRA is GBP 300 -- the same as if the benefit were provided without salary sacrifice. The employee saves no income tax and no employee NIC. The employer remains liable for Class 1A NIC at 15% (GBP 45) on the benefit, or for secondary Class 1 NIC on the salary if the salary amount produces a higher NIC charge, whichever is greater.

The comparison is instructive:

Delivery method Employee income tax Employee NIC Employer NIC Total tax/NIC cost
Employer-funded BiK (GBP 300) GBP 120 (at 40%) Nil GBP 45 (Class 1A at 15%) GBP 165
Salary sacrifice (GBP 300) GBP 120 (at 40%) Nil (OpRA) GBP 45 (Class 1A at 15%) GBP 165
Employee self-funded (gross cost) N/A N/A N/A GBP 300 (from net pay)

The salary sacrifice route delivers no tax advantage over straightforward employer provision for will writing services. Benefits compliance officers should verify that any provider marketing materials accurately reflect the OpRA position and should avoid salary sacrifice structuring that adds administrative complexity without tax benefit.16

4. Mandatory Payrolling from April 2027

4.1 The Reporting Transition

From 6 April 2027, employers must report benefits in kind and taxable employment expenses through the Full Payment Submission (FPS) process via payroll software, replacing the annual P11D submission.4 This change, originally planned for April 2026, was delayed by one year following representations from employers, payroll professionals, and software providers regarding implementation readiness.4

The expanded FPS data fields will capture the information currently reported via P11D and P11D(b), enabling real-time reporting of income tax and Class 1A NIC on benefits.4 Employers will not require special registration for most benefits, though loans and accommodation are subject to separate provisions. HMRC has confirmed transitional relief for the 2027-28 tax year: penalties will not be imposed for inaccurate reporting unless deliberate non-compliance is established, though standard late-filing and late-payment penalties remain in force.4

4.2 Operational Implications for Will Services

Will writing benefits present a specific reporting challenge under mandatory payrolling. Unlike recurring benefits such as company cars or medical insurance, will services are typically provided episodically -- through annual workplace "will surgery" events, on-demand referral, or as part of periodic benefits enrolment windows. The employer must allocate the benefit value to relevant pay periods within the FPS cycle.

HMRC guidance permits the use of reasonable estimates where exact benefit values are unknown at the start of the tax year, with reconciliation at year-end.4 Benefits teams should establish with their will writing provider a data-sharing protocol that delivers individual benefit values in a format compatible with payroll software import requirements. The transition period provides an implementation window, but systems testing and process documentation should commence well before April 2027.

5. Consumer Protection and Procurement Due Diligence

5.1 The CMA's Enforcement Framework

The consumer protection enforcement provisions of the Digital Markets, Competition and Consumers Act 2024 came into force on 6 April 2025, fundamentally altering the compliance landscape for unregulated service providers.3 The CMA now has the power to directly enforce consumer protection law through administrative action, with fines of up to 10% of global turnover for consumer law breaches.3 The enhanced unfair commercial practices regime includes prohibitions on drip pricing, subscription traps, and misleading omissions. The Secretary of State retains power to add to the list of automatically unfair practices via secondary legislation.3

The CMA's January 2026 updated guidance for unregulated will writing providers addresses pricing transparency, contract terms, complaints handling, and advertising standards.6 While these obligations fall directly on the will writing provider, the employer sponsor bears vicarious reputational risk where services procured under the employer's brand or benefit scheme fail to meet consumer protection standards. An employee who receives substandard will writing through an employer-sponsored scheme is likely to attribute responsibility -- at least in part -- to the employer.

5.2 Provider Due Diligence Framework

Benefits compliance officers should apply a structured due diligence framework when selecting will writing providers. The following checklist addresses the key risk dimensions:

Regulatory and professional standing:

  • SRA authorisation status (if applicable) or membership of a recognised voluntary body such as the Society of Will Writers
  • Professional indemnity insurance: minimum GBP 2 million (SWW standard) with confirmation of policy currency10
  • Complaints handling procedure compliant with CMA guidance
  • Evidence of CPD compliance for practitioners

Consumer protection compliance:

  • Pricing transparency: clear, upfront pricing without drip-pricing or undisclosed add-ons
  • Contract terms: fair terms compliant with the Consumer Rights Act 2015 and DMCCA 2024
  • Advertising: no misleading claims regarding scope, quality, or legal standing of services
  • Refund and cancellation policy consistent with CMA expectations6

Operational capability:

  • Capacity to accommodate diverse cultural, religious, and family requirements
  • Accessible service delivery (remote consultations, accessible documents, reasonable adjustments)
  • Data security certifications and UK GDPR compliance (see Section 6)
  • Payroll-compatible benefit reporting for mandatory payrolling readiness

Quality assurance:

  • Sample wills reviewed by independent legal counsel
  • Client satisfaction data and complaint volumes
  • Document storage and retrieval provisions
  • Process for updating wills following changes in law or client circumstances

The distinction between SRA-authorised firms and unregulated providers warrants careful consideration. SRA-authorised firms are subject to the SRA Standards and Regulations, mandatory professional indemnity insurance through the SRA's minimum terms, access to the Solicitors Disciplinary Tribunal, and client access to the Legal Ombudsman's complaints scheme.9 Unregulated providers may offer competitive pricing but lack these protections, placing greater emphasis on contractual safeguards and ongoing monitoring by the employer sponsor.

6. Data Protection Compliance

6.1 Lawful Basis Under UK GDPR

Sharing employee personal data with a third-party will writing provider requires a lawful basis under UK GDPR Article 6.7 Two bases are most commonly applicable. Article 6(1)(a) -- consent -- operates where the employee affirmatively opts in to the benefit scheme and consents to data sharing. Article 6(1)(f) -- legitimate interests -- applies where the employer's interest in providing the benefit, balanced against the employee's privacy rights through a legitimate interests assessment, justifies the processing. Given the sensitivity of the data involved and the voluntary nature of the benefit, consent is generally the more defensible basis, provided it is freely given, specific, informed, and unambiguous.

6.2 Special Category Data

Will writing services may involve the processing of special category data under UK GDPR Article 9, including religious beliefs (relevant to Sharia-compliant wills and other faith-specific estate planning), health data (where incapacity planning or Lasting Powers of Attorney are included), and data concerning family relationships and dependants.7 Processing special category data requires an additional condition under Article 9(2), and the employer must have an appropriate policy document in place as required by Schedule 1, Part 1 of the Data Protection Act 2018.17

6.3 Data Protection Impact Assessment

A Data Protection Impact Assessment may be required under UK GDPR Article 35 where the processing involves systematic sharing of employee personal data with a third party, particularly at scale.18 The ICO's guidance identifies large-scale processing of special category data and systematic monitoring as triggers for a mandatory DPIA.18 Even where a DPIA is not strictly required, conducting one represents good practice and demonstrates accountability under the UK GDPR's governance framework.

6.4 Operational Requirements

The following data protection measures should form part of any employer will services arrangement:

  • Privacy notice: Employees must be informed of data sharing with the will writing provider, the purposes of processing, and their rights
  • Data processing agreement: A written agreement between employer and provider satisfying UK GDPR Article 28 requirements
  • Data minimisation: Only personal data necessary for service delivery should be shared; no bulk transfer of HR records
  • Opt-out without detriment: Employees must be able to decline participation without adverse employment consequences
  • Retention and deletion: Clear provisions for the retention period and secure deletion of employee data held by the provider

7. Equality Act 2010 and Inclusive Benefits Design

The Equality Act 2010 prohibits direct and indirect discrimination in relation to terms and conditions of employment, which encompasses the provision of voluntary benefits.8 Employer-sponsored will services must be designed and delivered in a manner that ensures equitable access across the workforce, engaging several protected characteristics.

7.1 Religious and Cultural Accommodation

Will provisions vary significantly across faith traditions. Islamic inheritance principles under Sharia allocate fixed shares to specified relatives, and Sharia-compliant will drafting requires practitioners with specific expertise. Jewish estate practices, Hindu succession customs, and other faith-based requirements similarly demand provider capability beyond standard English law will drafting.8 Benefits compliance officers should verify that contracted providers can accommodate diverse religious and cultural requirements, or that employees with such requirements are not disadvantaged by a provider unable to meet their needs.

7.2 Family Structure and Accessibility

Benefits design must avoid indirect discrimination against employees in non-traditional family structures, including cohabiting partners, blended families, and same-sex partnerships. Will writing consultations must be accessible to employees with disabilities, including provision for remote consultations, documents in accessible formats, and reasonable adjustments consistent with the employer's duty under the Equality Act.8 Part-time and flexible workers should have access to will services on equivalent terms, avoiding eligibility criteria that disproportionately exclude employees working non-standard patterns.

This dimension connects directly to the broader diversity, equity, and inclusion agenda within benefits strategy. The CIPD's guidance on inclusive benefits design emphasises that benefit provision should be audited for potential indirect discrimination and that employee feedback mechanisms should capture whether benefits meet the needs of a diverse workforce. Will services -- often designed around assumptions of nuclear family structures and English law principles -- are a category where inclusive design is particularly important yet frequently overlooked.

8. Strategic Context: Pension Death Benefits and the Case for Integrated Estate Planning

From 6 April 2027, unused pension funds and most pension death benefits will be included in the deceased's estate for inheritance tax purposes.5 Personal representatives, rather than scheme administrators, bear primary responsibility for reporting and paying IHT on pension assets.5 The Government estimates that 10,500 estates will become newly liable for IHT and 38,500 estates will pay increased IHT as a result, with an average increase of approximately GBP 34,000 per estate.5

Death-in-service benefits paid from a registered pension scheme are excluded from IHT scope, as are dependant's scheme pensions from defined benefit and career average arrangements.5 This distinction is critical for employer communications: employees contributing to defined contribution workplace pensions face potential IHT exposure on accumulated funds, while those with defined benefit entitlements receive partial insulation.

The pension death benefit change creates a strategic rationale for employers to position will writing services within a coherent death-in-service, pension, and estate planning communications framework. Employees with significant pension funds will require wills that address pension death benefit nominations alongside traditional asset distribution. Nomination forms for pension death benefits should be reviewed in conjunction with will provisions to avoid conflicting instructions -- a risk that is especially acute where employees have completed pension nomination forms many years prior to making a will, or vice versa.

The broader benefits compliance landscape continues to evolve: the Employment Rights Act 2025, which received Royal Assent on 18 December 2025, introduces phased reforms through 2027 -- including day-one paternity and parental leave rights from April 2026 -- that are reshaping benefits strategy and compliance infrastructure.19 Benefits teams already preparing for ERA 2025 implementation should leverage the same compliance review cycle to address will services governance ahead of the April 2027 mandatory payrolling and pension IHT deadlines.

The Law Commission published its final report, Modernising Wills Law, on 16 May 2025, including a draft Bill recommending the enabling of electronic wills with specific safety requirements.20 If implemented, electronic wills provisions could transform the delivery model for employer-sponsored services, enabling digital completion and storage. The report also recommends judicial dispensing power (allowing courts to validate documents not meeting all formalities where testamentary intent is established) and reduction of the minimum testamentary age from 18 to 16.20 Implementation remains subject to Government response and parliamentary time.

Conclusion

Employer-sponsored will writing services demand a compliance framework that spans at least five regulatory domains: employment tax under ITEPA 2003, consumer protection under the DMCCA 2024, data protection under UK GDPR, equality law under the Equality Act 2010, and professional regulation (or its absence) under the Legal Services Act 2007. Most benefits teams treat will writing as a low-complexity voluntary benefit; the regulatory architecture demonstrates otherwise.

The April 2027 date represents a dual compliance trigger. Mandatory payrolling of benefits in kind requires will services to be integrated into FPS reporting cycles, replacing the annual P11D process.4 Simultaneously, the inclusion of pension death benefits in IHT creates heightened demand for coordinated estate planning, strengthening the strategic case for employer will services while adding urgency to the compliance framework for their delivery.5

Benefits compliance officers should use the implementation window before April 2027 to audit existing will service arrangements against the framework outlined in this article, engage with payroll and HR technology teams on reporting readiness, and review provider contracts against CMA guidance and data protection requirements. Where will services have been procured historically without structured due diligence, a comprehensive provider review is warranted.

The modern HR function differentiates itself through compliance capability in benefit categories that others treat as administrative afterthoughts. Employer will services are precisely such a category: voluntary, apparently simple, and -- upon examination -- subject to a compliance architecture of considerable depth and consequence.

CPD Declaration

Estimated Reading Time: 21 minutes Technical Level: Advanced Practice Areas: Employee Benefits Compliance, Employment Tax, Procurement Governance, Data Protection

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the regulatory bodies and legislative instruments governing employer-sponsored will writing services, including the Legal Services Act 2007, ITEPA 2003, DMCCA 2024, UK GDPR, and the Equality Act 2010
  2. Evaluate the tax treatment of employer-provided will services under the benefit in kind, trivial benefit exemption, welfare counselling exemption, and optional remuneration arrangement frameworks
  3. Apply a procurement due diligence framework when selecting will writing providers, distinguishing between SRA-authorised firms and unregulated providers
  4. Analyse the interaction between pension death benefit IHT inclusion from April 2027 and the strategic case for employer-sponsored estate planning services

Competency Mapping

  • CIPD Associate Level: Employment Law and Employee Relations -- regulatory compliance in benefits administration
  • CIPD Advanced Level: Reward Management -- tax-efficient benefits design and governance
  • HMRC Agent Competency: Benefits in Kind reporting and payrolling obligations

Reflective Questions

  1. How would the organisation's current benefits compliance framework need to adapt to accommodate the mandatory payrolling of will writing services from April 2027?
  2. What additional data protection safeguards should be implemented before sharing employee personal data with a third-party will writing provider?
  3. How might the April 2027 pension death benefit IHT change affect the strategic positioning of will services within the organisation's benefits package?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-25. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. Legal Services Act 2007 c.29, Schedule 2. https://www.legislation.gov.uk/ukpga/2007/29/schedule/2 ↩ ↩2 ↩3

  2. Income Tax (Earnings and Pensions) Act 2003, Part 3 Chapter 10. https://www.legislation.gov.uk/ukpga/2003/1/part/3/chapter/10 ↩ ↩2 ↩3

  3. Digital Markets, Competition and Consumers Act 2024 c.13. https://www.legislation.gov.uk/ukpga/2024/13/contents ↩ ↩2 ↩3 ↩4 ↩5

  4. GOV.UK: Technical Note -- Mandating the reporting of benefits in kind and expenses through payroll software -- an update. https://www.gov.uk/government/publications/reporting-and-paying-income-tax-and-class-1a-national-insurance-contributions-on-benefits-in-kind-in-real-time-an-update/technical-note-mandating-the-reporting-of-benefits-in-kind-and-expenses-through-payroll-software-an-update ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  5. GOV.UK: Inheritance Tax -- unused pension funds and death benefits. https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  6. GOV.UK: CMA Case -- Will writing and other unregulated legal services. https://www.gov.uk/cma-cases/will-writing-and-other-unregulated-legal-services ↩ ↩2 ↩3 ↩4 ↩5

  7. UK GDPR Article 6 -- Lawfulness of Processing. https://www.legislation.gov.uk/eur/2016/679/article/6 ↩ ↩2 ↩3

  8. Equality Act 2010 c.15. https://www.legislation.gov.uk/ukpga/2010/15/contents ↩ ↩2 ↩3 ↩4

  9. SRA Guidance: Does my employer need to be authorised by an approved regulator? https://www.sra.org.uk/solicitors/guidance/employer-need-authorised-approved-regulator/ ↩ ↩2

  10. Society of Will Writers: Code of Practice. https://www.willwriters.com/about-us/code-of-practice/ ↩ ↩2 ↩3

  11. GOV.UK: Rates and thresholds for employers 2025 to 2026. https://www.gov.uk/guidance/rates-and-thresholds-for-employers-2025-to-2026 ↩ ↩2

  12. Corporation Tax Act 2009, s.54 (Expenses not wholly and exclusively for trade). https://www.legislation.gov.uk/ukpga/2009/4/section/54 ↩

  13. Income Tax (Earnings and Pensions) Act 2003, Section 323A. https://www.legislation.gov.uk/ukpga/2003/1/section/323A ↩ ↩2

  14. HMRC Employment Income Manual EIM21845: Particular benefits -- exemption for welfare counselling. https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim21845 ↩ ↩2

  15. GOV.UK: PAYE Settlement Agreements. https://www.gov.uk/paye-settlement-agreements ↩

  16. GOV.UK: Optional Remuneration Arrangements. https://www.gov.uk/government/publications/optional-remuneration-arrangements/optional-remuneration-arrangements ↩ ↩2 ↩3 ↩4

  17. Data Protection Act 2018, Schedule 1 Part 1. https://www.legislation.gov.uk/ukpga/2018/12/schedule/1 ↩

  18. ICO: Data Protection Impact Assessments. https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/accountability-and-governance/data-protection-impact-assessments-dpias/ ↩ ↩2

  19. GOV.UK: Employment Rights Act 2025 Factsheets. https://www.gov.uk/government/publications/employment-rights-bill-factsheets ↩

  20. Law Commission: Wills Project -- Modernising Wills Law. https://lawcom.gov.uk/project/wills/ ↩ ↩2

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