
Rules and ethics
Influencer platform campaigns: how HMRC treats gifts and affiliate pay
For UK brands paying creators through an influencer platform: how HMRC treats gifted products and affiliate commission, and the tax clauses to agree first.
A brand or agency that finds creators through an influencer platform usually pays them in more than cash: gifted products, discount codes and affiliate commission tracked through the platform or a network. Each of those is part of the creator's taxable income, and each lands in the brand's own campaign records. This guide explains how HMRC treats them on the creator's side, what that means for the records a brand should keep in or beside its platform, and the tax clauses to settle in the creator contract before a campaign goes live.
What to take away
- Gifted products, fees and affiliate commission are all trading income for HMRC, declared at market value rather than at zero.
- VAT registration starts at £90,000 of turnover in any rolling 12 months, and promotional services are standard rated at 20 per cent.
- Making Tax Digital for Income Tax begins above £50,000 of qualifying income, replacing one annual return with quarterly updates.
- Contracts should settle gift valuation, VAT status, evidence and any gross-up before a campaign goes live.
When a gifted product becomes taxable trading income
A creator who posts in return for a reward is trading. HMRC does not distinguish between a bank transfer, a discount code and a box of skincare.
Market value is the figure to declare: the price a buyer would pay, not the wholesale cost the brand paid. The test is commercial, not the creator's own view of the item.
What counts as trading income
Taxable trading income
- Cash fee
- Yes
- Gifted product
- Yes
- Discount code
- Yes
- Affiliate commission
- Yes
- Agency fee
- Yes
Not trading income
- Cash fee
- No
- Gifted product
- No
- Discount code
- No
- Affiliate commission
- No
- Agency fee
- No
Unsolicited items with no brief, no deadline and no usage request fall outside this. On the brand's side, HMRC's business gift rule applies where gifts to one person pass £50 in 12 months.
Reporting gifts and commission on Self Assessment
Self Assessment is how most creators declare this income. The Self Assessment tax returns: Overview - GOV.UK page sets out who must file and the 31 January online deadline.
Gifts go in at market value, fees at the invoiced amount and commission at the amount received or receivable. Expenses wholly and exclusively for the trade reduce the taxable figure.
Keep the file even for small campaigns, because the UK rules that reach creator discovery cover the data and disclosure duties beside the tax record.
Example: one creator's tax year in figures
A sole trader with 12,000 TikTok followers earns £22,000 in cash fees, £9,600 in affiliate commission and 34 gifted items valued at £200 each.
One creator's tax year
| Item | Amount | Treatment |
|---|---|---|
| Cash fees | £22,000 | Trading income, invoiced |
| Affiliate commission | £9,600 | Trading income when earned |
| Gifted products | £6,800 | Trading income at market value |
| Allowable expenses | £4,200 | Deducted from income |
| Taxable profit | £34,200 | Below the £50,000 MTD start line |
Turnover of £38,400 stays under the £90,000 VAT threshold, so no VAT is charged. When commission counts depends on the creator's accounting method. GOV.UK describes cash basis as the standard way for a sole trader to record income, counting it when the money is received, so under cash basis commission earned in March but paid in June falls in the later tax year. A creator who chooses traditional accounting records income by the date it was invoiced, and the same commission stays in the earlier year.
What the brand's platform records should hold
The creator can only value a gift or reconcile commission if the brand's records say what was sent, when, and what was asked in return. Whether campaigns run through an influencer platform or a spreadsheet, keep for each creator:
- every gifted item, with its retail price on the date it was sent and the brief, deadline or usage request attached to it;
- each fee, invoice number and VAT status;
- the affiliate or discount-code statement for the period, matched to what was actually paid out;
- unsolicited items sent with no brief, recorded separately so they are not mistaken for payment in kind.
A summary of those rows, sent to the creator at the end of the campaign, answers most of the questions an accountant or HMRC will ask, and it is the evidence the contract clauses below rely on.
VAT on gifts, commission and agency fees
Three supplies can sit in one campaign, each with its own treatment. The VAT rates on different goods and services - GOV.UK confirms most promotional services are standard rated at 20 per cent.
VAT on gifts and fees
| Element | Supplier | VAT position |
|---|---|---|
| Cash fee | Creator to brand | 20 per cent when the creator is registered |
| Affiliate commission | Network to retailer | Standard rated marketing services |
| Agency fee | Agency to brand | Invoiced separately, standard rated |
A gifted product is not a VAT-free sample when promotion is given in return. Place of supply decides whether UK VAT applies, so a London brand paying a creator in Glasgow is domestic.
Platform fees are often the hidden costs that never appear on the platform invoice, so request a VAT-inclusive quote before budgeting.
Making Tax Digital thresholds and quarterly records
From April 2026, sole traders and landlords with qualifying income over £50,000 must keep digital records and send quarterly updates. That threshold falls to £30,000 from April 2027.
The Making Tax Digital for Income Tax: step by step - GOV.UK collection sets out the sequence:
MTD thresholds and records
- Sign up once qualifying income passes the threshold.
- Choose compatible software, or a spreadsheet connected to it.
- Record every transaction with a date, amount, counterparty and category.
- Value gifted products on arrival and reconcile affiliate statements to payouts.
Making Tax Digital quarterly cycle
- Sign up to the regime
- Keep digital records
- Send quarterly updates
- Submit final declaration
Tax clauses to agree before the campaign goes live
Contract clauses decide which creators finance can approve without a queue of exceptions. List fees, gifts, commission and discounts separately, then state who accounts for tax on each.
Tax clauses to agree
- Valuationthe brand records market value for each gifted item at the point of supply.
- VATstate whether figures are inclusive or exclusive, and what changes if the creator registers mid-campaign.
- Evidencethe creator keeps records and supplies a summary on request, not a full return.
- Gross-upagree who bears extra tax if HMRC recharacterises a payment, and cap the exposure.
- Exita route out when compliance evidence is missing, without breaching consumer law.
The contract questions to ask a creator discovery supplier about data and exit cover the platform side of the same file.
What an HMRC compliance check costs
An enquiry usually opens with a records request covering two or three years. Penalties for careless inaccuracies reach 30 per cent of the tax due, 70 per cent where the error is deliberate and 100 per cent where it is concealed.
Late filing adds £100 at once, then £10 a day after three months capped at £900, plus 5 per cent of the tax due at six and twelve months.
A complete gift valuation and a reconciled commission statement turn most of these into a short exchange.
Common questions
Do gifted products count as income if the creator never posts?
A genuine unsolicited gift with no brief, deadline or usage request is not trading income. Once a post is requested, the market value becomes taxable.
Is affiliate commission taxable before the payout arrives?
It depends on the creator's accounting method. Under cash basis, the standard method for sole traders, income is recorded when the money is received, so commission earned in March and paid in June belongs to the later tax year. Under traditional accounting it is recorded by invoice date and belongs to the earlier year.
What records does Making Tax Digital require?
Digital records with a date, amount, counterparty and category for each transaction. Gifted products need a valuation and a note of what was supplied in return.



