DKB-Sheffield
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Old VAT Returns - Online Cutoff?

Old VAT Returns - Online Cutoff?

Dear All,

I have recently been approached by a client wishing me to file VAT returns dating back to 2008!!! 

Aside from my obvious major concerns and issues surrounding the extended matter (HMRC involvement, penalties, surcharges, interest)...... the list is extensive, I am interested in hearing the practicalities of this, in particular:

  1. How far back can we go for submitting returns online? I see no references to a deadline for submission (unlike Self Assessment, CT etc.)
  2. If we can't submit returns online as far back as 2008, do HMRC still have a "stock" of manual VAT returns or can we use the "substitute" returns produced by our software?

Whether or not the above is possible will not really sway my decision to represent this client (there is clearly so much more at stake that "how" the returns are filed). However, it would certainly be interesting to know HMRC do impose an online filing cutoff.

I look forward to hearing your thoughts.

Many thanks and kind regards!

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03rd Mar 2016 15:41

I would have thought in such a case the sensible approach would be to talk to HMRC first and seek permission to submit all the late ones as one return then do one exercise in collating all the VAT information the client has, calculating the figures and settling up all in a one.

Indeed I'm not sure why anyone would consider doing things any other way, surely you're not proposing preparing and filing 30+ quarterly returns instead, are you?

Thanks (1)
03rd Mar 2016 17:48

@ Duggimon

Hi,

Thanks for your reply!

Ordinarily... "no", I would not submit individual VAT returns and would look to agree an alternative with HMRC however... the client is adamant that HMRC are insisting that individual returns are filed for the entire period. Not sure I believe this though!

Clearly, this is a new (or should I say, at this stage and given the circumstances, a "prospective" client) and hence I have no 64-8 in place. As a result, I cannot confirm or deny HMRC's stance.

Thanks anyway!

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03rd Mar 2016 17:55

Adamant ?

DKB-Sheffield wrote:

Hi,

Thanks for your reply!

Ordinarily... "no", I would not submit individual VAT returns and would look to agree an alternative with HMRC however... the client is adamant that HMRC are insisting that individual returns are filed for the entire period. Not sure I believe this though!

Clearly, this is a new (or should I say, at this stage and given the circumstances, a "prospective" client) and hence I have no 64-8 in place. As a result, I cannot confirm or deny HMRC's stance.

Thanks anyway!

HMRC choose the return periods, not the client.

Just saying, like.

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03rd Mar 2016 15:54

Not sure but....

I don't know the answer but I reckon if you send them the figures and a cheque they'll just say 'thanks very much'!

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03rd Mar 2016 17:45

Depends

Is this a late registration ?

If it is, HMRC have always asked for one return from the EDR to the next return date after the application is received.   The biggest one I've done is three and a bit years, April 1973 to May 1976.  The biggest problem was working out the Purchase Tax Rebate.

If, on the other hand, he's been registeredfor seven years without submitting a return, I'm surprised it's been left to drift so long.

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03rd Mar 2016 17:57

Well...

Thank you for your feedback.

This was indeed my first question to the client as I am absolutely amazed this could have gone unnoticed. Indeed, the last time I carried something like this out for a client who was already VAT registered, the had been served a Winding Up Petition. The difference was, that was for non-submission of returns spanning 6 quarters not 7 years!

Personally, I smell a rat and think I'll be "jumping"!!!

My main query was regarding the possibility of filing historic quarters and, I think I have found the answer! I don't believe there is any limit - as long as it is an open period on HMRC Online (unless of course somebody knows differently)

Thanks again for your response.

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04th Mar 2016 16:07

I would be surprised to find there were open periods on HMRC online pre-dating HMRC online. I would also agree with you that it sounds extremely doubtful that HMRC have requested separate returns. I would be asking for a copy of all correspondence to see what they've actually said before proceeding with any work.

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