Redundancy + termination → PILON + PENP formula
PILON + PENP — Post-April 2018 Reform + Formula (ITEPA 2003 s.402D + HMRC EIM13880)
Before 6 April 2018, only CONTRACTUAL PILON was automatically taxable; non-contractual PILON could fall within the £30,000 termination payment exemption. Finance (No. 2) Act 2017 ended that distinction — ITEPA 2003 s.402A-E now require ALL pay-in-lieu-of-notice slices to be taxed as ordinary employment income, regardless of whether the contract mentions PILON. The mechanism is the Post-Employment Notice Pay (PENP) calculation under s.402D: PENP = (BP × D) / P − T, where BP is basic pay in the last pay period; D is the number of unworked days in the minimum statutory or contractual notice period; P is the number of days in the last pay period; and T is the sum of any amounts already characterised as PILON in the termination package. Per HMRC EIM13880. The PENP slice is fully taxable (PAYE + employee NIC + employer NIC) and CANNOT use the £30,000 exemption.
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In plain English
If your employer terminates without making you work your full notice, the part of any payment that represents the unworked notice period must be taxed as ordinary salary — even where the contract doesn't have a PILON clause and the payment is labelled 'compensation'. This rule has applied since 6 April 2018. The calculation that HMRC requires is called PENP — Post-Employment Notice Pay. The formula is in ITEPA 2003 s.402D and HMRC EIM13880: PENP = (BP × D) / P − T where: • BP = your basic pay in the last full pay period before notice was given • D = the number of days of statutory or contractual minimum notice that you did NOT work • P = the number of days in your last pay period (e.g. 30 or 31 for a monthly-paid worker) • T = anything in the termination package already explicitly described as PILON (to avoid double-counting) The PENP amount is taxed as employment income with PAYE, employee NIC and employer NIC — it cannot sit inside the £30,000 s.401 exemption. The rest of the termination package (true ex-gratia for loss of office, statutory redundancy, non-PILON enhanced redundancy) is then analysed under the s.401 regime as normal — first £30k tax-free, excess taxable at marginal rate but no employee NIC.
How it works
Why the rule changed (April 2018)
Pre-April 2018, distinguishing contractual PILON (taxable) from non-contractual PILON (potentially within £30k exemption) created planning opportunities and HMRC disputes. The PENP regime removes the distinction — all unworked-notice-equivalent payments are taxed the same way, regardless of contract drafting.
The PENP formula (s.402D / EIM13880)
PENP = (BP × D) / P − T. BP is basic pay in the last pay period before notice was given — usually salary only; bonuses and most benefits in kind are excluded. D is the number of unworked days within the relevant notice period (statutory minimum under ERA 1996 s.86, or contractual minimum if longer). P is the number of days in the last pay period (commonly 30 or 31 for monthly paid). T is amounts in the package the employer has already labelled and taxed as PILON — included to avoid double-counting.
Salary sacrifice trap
BP is sometimes calculated by reference to pre-sacrifice salary in particular salary-sacrifice scenarios. HMRC's view in EIM13890+ has evolved; check the latest manual entry before relying on a sacrificed-salary calculation that produces a low PENP.
Worked-notice scenario
If the employee works the full statutory + contractual notice period before leaving, D = 0 and PENP is zero — no PENP charge on any ex-gratia package. This is why some leavers negotiate 'garden leave' (worked notice on full pay) rather than PILON — to preserve the £30k exemption headroom on the ex-gratia top-up.
Interaction with statutory redundancy + £30k
PENP comes off the top of the termination package before the s.401 / £30k regime applies. So: total package − (contractual amounts) − PENP = the s.401 slice, of which £30k is tax-free. Statutory redundancy stays inside the s.401 slice and counts towards the £30k cap.
Who this applies to + key conditions
- Applies to any UK employment termination on or after 6 April 2018
- Applies whether or not the contract contains a PILON clause
- Applies whether the package is structured as PILON, ex-gratia, compensation for loss of office, or settlement payment
- PENP is computed by reference to the statutory or contractual minimum notice — whichever is longer
Statute + manual references
Primary: ITEPA 2003 sections 402A to 402E (inserted by Finance (No. 2) Act 2017) — Post-Employment Notice Pay (PENP) regime. s.402D contains the formula.
Related: ITEPA 2003 s.401-416 — surrounding termination payment regime; Employment Rights Act 1996 s.86 — statutory minimum notice periods; Finance (No. 2) Act 2017 — introduced PENP and abolished Foreign Service Relief from 6 April 2018
HMRC manual: EIM13874 (PENP overview); EIM13880 (formula and worked examples); EIM13890+ (special cases including monthly vs weekly pay periods, salary sacrifice)
Common mistakes + traps
- Treating non-contractual PILON as £30k-exempt — that planning ended on 6 April 2018
- Using gross pay including bonuses + BiKs as BP — generally BP is basic salary only
- Using contractual notice when the statutory minimum is longer (or vice versa) — use the GREATER of the two
- Forgetting to deduct T — leads to double-counting and over-taxation
- Not running PENP at all in settlement-agreement scenarios — HMRC enquires aggressively where £30k is fully utilised but no PENP shown
Worked example
Aisha, monthly-paid, basic salary £4,500/month, 6 months' contractual notice, employer terminates with no worked notice (full PILON)
Aisha's termination package: £27,000 labelled 'compensation for loss of office' (no explicit PILON line). Her last pay period was 30 days (April).
- Step 1 — Identify D: 6 months' notice not worked. Assume D = 183 unworked days (6 months × roughly 30.5).
- Step 2 — Identify BP: £4,500 basic monthly salary.
- Step 3 — Identify P: 30 days (April).
- Step 4 — Identify T: zero — nothing in package explicitly labelled as PILON.
- Step 5 — Apply formula: PENP = (4,500 × 183) / 30 − 0 = 823,500 / 30 = £27,450.
- Step 6 — All £27,000 of the 'compensation' is reclassified as PENP (capped at the actual package value; HMRC does not impose PENP above what was actually paid). It is taxed as ordinary employment income with PAYE + employee + employer NIC.
- Step 7 — No £30k exemption is available because the entire £27,000 is PENP. If the package had been £40,000, then £27,450 would be PENP (PAYE + NIC) and the remaining £12,550 would fall into the s.401 slice — within the £30k cap and tax-free.
Outcome: Aisha's £27,000 is taxed entirely as ordinary employment income via PENP — no £30k exemption applies. Net to Aisha depends on her marginal rate. A larger ex-gratia top-up beyond PENP would have qualified for the £30k cap.
How this connects to the rest of the framework
PENP comes off the top; only the remainder qualifies for the £30k s.401 exemption.
Settlement agreements must explicitly identify the PENP slice and tax it correctly via PAYE.
Statutory redundancy is separate from PENP and is unaffected by it.
Worked scenarios show PENP calculations for monthly-paid employees with varying notice periods.
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
What if my contract has a generous notice period that exceeds what was paid?+
Does PENP apply to redundancy pay?+
Can I avoid PENP by working garden leave?+
Are bonuses included in BP?+
Free + regulated-body resources
- HMRC EIM13880 — PENP formula →
Authority on the PENP calculation
- HMRC EIM13874 — PENP overview →
Entry point for PILON / PENP regime
- ACAS — notice periods →
Statutory + contractual notice guidance
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