Most property company directors currently find out what tax they owe on a company car, health cover or a cheap director's loan months after the tax year has ended, when the P11D lands with the annual accounts. From April 2027, HMRC is making real-time payrolling of benefits in kind mandatory for most employers, which means tax starts coming out of pay as the benefit is provided, rather than arriving as a bill the following year.
What's actually changing
Under the current system, most employers report benefits in kind — company cars, private medical insurance, cheap or interest-free loans, and living accommodation among them — annually on form P11D after the tax year ends, with the employer's Class 1A National Insurance reported and paid separately via a P11D(b) by 22 July following. The employee's own income tax on the benefit is then usually collected later, through an adjustment to their PAYE tax code or via self assessment. From April 2027, HMRC intends to make it mandatory for employers to payroll most benefits instead — reporting and taxing them through the payroll in real time, in the same pay run as salary, rather than after the event. The change was originally due to start a year earlier, in April 2026, before HMRC pushed the mandate back by a year to give employers, agents and payroll software more time to get ready.
You can already do this voluntarily
Payrolling most benefits in kind voluntarily is already possible, and has been for some years — an employer registers with HMRC through PAYE Online before the start of the tax year it wants to start from, then reports the taxable value of benefits through payroll rather than by P11D. Property companies that already provide a director with a company car, medical insurance or a loan can start payrolling now, ahead of the mandate, and get their systems and reporting bedded in before it becomes compulsory. One wrinkle worth knowing: even under voluntary payrolling today, Class 1A National Insurance on the benefit is still usually reported and paid via an annual P11D(b), separately from the real-time payrolling of the employee's income tax — it's the employee side of the reporting that moves into payroll first.
Loans and accommodation are the awkward cases
Most benefits translate reasonably cleanly into a payroll figure each pay period. Interest-free or low-interest director's loans and living accommodation are harder, because their taxable value depends on a running balance or an ongoing arrangement rather than a fixed annual figure, and can move during the year. HMRC has acknowledged these are more complicated to payroll in real time and has signalled it will keep working through the detail with employers and software providers before the mandate lands — so a property company with a director's loan account already sitting in section 455 territory, or providing accommodation to a site manager, should watch this space rather than assume the mechanics are settled.
Why this matters for property company directors specifically
Director's loan accounts are common in property companies, drawn down against development profit and often running for a year or more before being cleared. Under the current system, the benefit in kind on an interest-free or cheap loan shows up on a P11D long after the loan was actually outstanding. Once payrolling becomes mandatory, that benefit starts being taxed through payroll as it accrues, which means the tax cost of running an interest-free loan becomes visible in real time rather than as a year-end surprise — worth factoring into how a company sets, or charges interest on, director loan balances going forward.
What this means in practice
If your company already provides benefits in kind to directors or staff, consider registering to payroll them voluntarily before the mandate arrives in April 2027, so the transition is a formality rather than a scramble. Review any director's loan account against HMRC's official rate for the interest actually charged, since that's the calculation that will start hitting payroll directly. And keep an eye on HMRC's guidance on loans and accommodation specifically, since those are the two benefit types most likely to see late changes before the mandate takes effect.
Common questions
When does mandatory payrolling of benefits in kind start?
HMRC intends to make payrolling of most benefits in kind mandatory from April 2027, having pushed the original April 2026 start date back by a year to give employers and payroll software more time to prepare.
Can I payroll benefits in kind before the mandate takes effect?
Yes. Voluntary payrolling is already available, and an employer can register with HMRC through PAYE Online before the start of a tax year to begin reporting and taxing most benefits through payroll rather than by P11D.
Does payrolling change how Class 1A National Insurance is reported?
Under current voluntary payrolling, Class 1A NIC on benefits is still generally reported and paid annually via form P11D(b), separately from the real-time payrolling of the employee's income tax. How this is handled under the mandatory regime from April 2027 is still being finalised.
Are director's loans and accommodation benefits included in mandatory payrolling?
They are intended to be covered, but HMRC has acknowledged these benefit types are harder to payroll in real time because their taxable value depends on a running balance or ongoing arrangement, and has said it will continue working through the detail with employers and software providers.
Kieran Holsgrove is a Director and Co-Founder of Grafene Accounting, the property tax specialist firm based in Liverpool. He advises property developers, investors and landlords across Merseyside, Greater Manchester, Lancashire and Cheshire on tax structuring, developer VAT, SDLT and the long-view decisions that compound over the life of a portfolio.
This article is general information, not personal tax advice, and tax rules change. Your own position depends on facts we cannot see from here — please take advice before acting on anything above.