I got 2 standard HMRC letters this morning about RTI - I'm sure you did, or will, too.
They are saying we shouldn't transmit details of P45/P46 online when RTI up and running.
They seem to imply that P46 will no longer be necessary. For new people without P45, I consider it essential that they fill in some sort of declaration to enable us to work out their starting tax code.
Maybe I've just misunderstood it all. Can anyone explain what we do if we aren't going to use a P46?
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No filing of forms P45 or P46 (or P35 or P14)
Under RTI, you will not need to submit any joiner or leaver information as the RTI submission itself covers everyone being paid by the employer. You will still have to issue form P45 to a leaver to take to his new employer so that they can pick up his PAYE code and gross pay and tax to date correctly. You can still ask starters without a P45 to complete a P46 - you just don't submit it to HMRC, just as you did not have to submit forms P38(S) for students.
And you still have to issue forms P60 to employees at 5th April, even though you will not be submitting the P14 to HMRC.
New Starters
You won't report new starters to HMRC separately any more. Their information will be automatically sent when you report your payroll information. So you'll need to have processes ready to collect and record the correct personal information from new starters. This information can be gathered and stored however you prefer - letter, email or a form. HMRC has a Starter Checklist you can use but this form, or any other records you keep, must not be sent to HMRC. Keep these records for at least two years.
I'd understood...
... that for ALL new starters (including those with a P45), you would now need to obtain a P46, because the P46 information is needed on the FPS, and the P45 hasn't got the employee declaration (boxes A-C)?
You may need P46's
but you don't need to send them to HMRC, details will be submitted with the RTI submission, that is all, so you receive process and put on your file.
HMRC Guidance
Here is the correct link to the HMRC Starter Checklist, but it is one of those irritating PDF forms which:
can only be completed on screenyou cannot progress to the next page until you have entered all the mandatory fields on the current pageyou can only print one page at a time.
It is just a rehash of the P46 without the employer details on the back page, but if you print the second page without filling anything in, it will serve as a blank form P46.
The guidance on getting information from new employees is more helpful.
Information form
It is a bit of a phaff, but if you have a pdf-writer, you can open a blank form and print to pdf. What is printed out is the full form, including the delcarations. If you then save this you have a blank master!
Printing HMRC StarterChecklist
You can print a blank version of the form without inputting any data. When you have the page that asks for the Employee's Personal Details, go to the printer icon in the toolbar. This will print a full blank Starter Checklist, including the details on page 2 of the online form.
Ronnie
No P46 question on P45(3)
It literally beggars belief that HMRC hasn't updated the P45(3) design to include space for asking the new P46 style declaration question. Then, at least once these started going through the system we wouldn't be collecting further bits of paper.
You have lost me
It literally beggars belief that HMRC hasn't updated the P45(3) design to include space for asking the new P46 style declaration question.
As a P46 only comes into play when there is no P45(3) produced by a starter, why would anyone want to amend the P45(3) to include a question that only applies if no P45(3) is produced?
And what is the "new P46 style declaration question"? Is it the old P46 Circumstances question? If so, Moonbeam could just use an old P46 without rehashing it.
Because P45 cases need it too
It literally beggars belief that HMRC hasn't updated the P45(3) design to include space for asking the new P46 style declaration question.
As a P46 only comes into play when there is no P45(3) produced by a starter, why would anyone want to amend the P45(3) to include a question that only applies if no P45(3) is produced?
And what is the "new P46 style declaration question"? Is it the old P46 Circumstances question? If so, Moonbeam could just use an old P46 without rehashing it.
Because under the new rules all new starters are required to do a P46 style A/B/C declaration, including those who produce P45s.
Thank you all!
I think what you are saying is that I can rehash an older version of a P46, add the declaration question and send it to my clients whose payroll is run by me, asking them to use that in future.
Thanks Tom
I am really concerned that this basic information is not spelt out by HMRC. Presumably there is lots more stuff that we are far too unimportant to be told.
If it's any help...
I asked HMRC during a live Twitter Q&A today and this was their response:
"No [to P46 being necessary]. Starter and leaver information will be reported on the FPS. Employers will still give employees a P45, but not send to..."
Unfortunately they did not continue past the three dots. Hope this helps!
P46 - don't use it any more
You don't need to use a P46 or any official form at all and you haven't since 2010. Many employers have added the P46 questions to their bank details form or offer letters whatever the employee is more likely to complete so they get paid! The key thing, as has been said, is that everyone must answer statement A, B or C and D (student loan) and.. if a P45 is presented but the employee ticks box C under RTI you ignore their coded and allocate BR/1, I hope HMRC then turn around the right code quickly if that was not what they meant to tick!
Printing P46
If you want a form with the same content, but slightly better layout, an introductory paragraph of Instructions to Employees and "P46" at the top instead of "Starter Checklist", you can print a blank version of the P46 (Short).