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RTI & your typical underpaid director

Twitter was alive with messages about this last night, following an online Q&A session with HMRC, even Rececca B posted.

Can someone say whether it has been confirmed that it will not be necessary to regularly report under RTI in this all too typical case?

Ta

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By Glennzy
20th Feb 2013 09:40

Notice of Codings

Hi Paul,

Slightly off post but I have some directors who receive minimum wage + dividends but also have about £5000 in rental income, which they have done for years.

I have just received their 2013/14 notice of coding and they have reduced the code by the rental income. Have you seen this before? Would you still put minimum wage through, pay the tax monthly then reduce next years POA to nil. 

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20th Feb 2013 10:12

Tick box

Glennzy wrote:

I have just received their 2013/14 notice of coding and they have reduced the code by the rental income. Have you seen this before? 

 

That's because you didn't tick box 3 on page 5 of the tax return. 

Note the astonishing hypocrisy here.  If you ask HMRC to collect £1,000 of tax from a basic director's salary, they'll write back and say that the salary is too low to collect that amount.  However, it's not too low to collect tax when it works in their favour.

 

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By Lucy J
20th Feb 2013 11:14

Get HMRC to amend code. Tell them client wishes to pay rental tax by SA.

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Astonishing

If you don't have to report regularly for directors taking eg threshold salary then that would be an astonishing turnabout by HMRC, who've struck very strongly to the "on or before" motif for all payments.

If the director receives a single annual payment you still need to file 11 nil EPS's for the other months (similar to current requirement to notify accounts office of nil payment). There is a specification for filing multiple nil EPS advance predictions in one go, but it is a little bit broken and potentially confusing.

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20th Feb 2013 11:20

Quarterly?

TomMcClelland wrote:

If the director receives a single annual payment you still need to file 11 nil EPS's for the other months (similar to current requirement to notify accounts office of nil payment). There is a specification for filing multiple nil EPS advance predictions in one go, but it is a little bit broken and potentially confusing.

Tom

Many of us notify nil PAYE due on a quarterly basis.  If we were to go the annual payment route, could we file 3 quarterly nil EPSs or is monthly filing obligatory?

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Nil EPS each month

Euan MacLennan wrote:

TomMcClelland wrote:

If the director receives a single annual payment you still need to file 11 nil EPS's for the other months (similar to current requirement to notify accounts office of nil payment). There is a specification for filing multiple nil EPS advance predictions in one go, but it is a little bit broken and potentially confusing.

Tom

Many of us notify nil PAYE due on a quarterly basis.  If we were to go the annual payment route, could we file 3 quarterly nil EPSs or is monthly filing obligatory.

Monthly filing of nil EPS is obligatory (discounting the wonky mechanism in the EPS for predictions until HMRC fixes it, which I think is planned for 2014/15). There is no quarterly concession that I am aware of. Certainly not mentioned in any RTI specifications I've seen.

The problem with the EPS nil prediction mechanism is that due to an HMRC specification error it doesn't allow predictions about the *current* PAYE month. So in the example of a single March payment to the director you'd have to do a prediction of nil May-Feb in April, then once you'd arrived in May you could do a normal nil EPS for April, which is so back to front that I think it would lead to more confusion and error (and endless clarification phone calls to payroll software suppliers :(( ) than it is worth. On that basis we decided it is too dangerous to offer it in 12Pay.

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Rebecca

Has made a number of conflicting tweets over RTI that I think she's just become static noise on the issue.

There should just bean ask Tom section on AWeb, in my view!

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By blok
20th Feb 2013 14:44

.

"static noise"

i quite like that one

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By Glennzy
20th Feb 2013 16:16

How are HMRC coping with RTI

I need to set up a few new PAYE schemes for the new tax year, with all the buzz around RTI how long are HMRC taking to set schemes up. They normally quote up to 6 weeks is this likely to be longer as distracted by RTI issues.

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Thanks to all

I'm wondering if it was more about salaries/wages below LEL, therefore no need for a scheme?  Maybe they will publish the Q&As?

blok, some of us are old enough to remember static noise on our short waves (or even crystal sets!)

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20th Feb 2013 22:35

more than a little hurt

I am not confused by this, nor are my tweets confused.

If a director is paid on account of earnings at or above LEL then filing an FPS is a requirement.

If a director is paid otherwise than on account of earnings, there are no PAYE /.NIC or RTI obligations in respect of that payment

If a director is paid on account of earnings an amount less than LEL then no FPS is necessary.

If an employer does not intend to make any payments for a specified future period they can file an inactivity report with dates inactive.

If an employer has no staff paid at or above LEL then no scheme is required, although you may want  a scheme to report benefits. File inactivity for the whole year - a single EPS.

Is that clear enough for you - or is this static noise?

I have spent a lot of my evenings over the last week responding to queries on RTI on Twitter which is the easiest way without giving out email addresses. I've chased up answers from HMRC and the Tax Faculty and tried to help as many people as I can. I really strongly object to bveing called static noise.

Very unhappy person.

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Many thanks Rebecca

The Tweet that sparked my question was:

"To avoid having to send in an EPS each month you should register as an annual scheme"//or poss inactivity report"

So it's the refernce to annual scheme that is of interest as I and 90% of my clients operate an annual salary.

 

 

 

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21st Feb 2013 00:07

ok Paul
I was quoting HMRC tweet but adding that inactivity (as opposed to Nil EPS) was also easy. One delegate paying director in Jan only prompted my comment. Simplest to do inactivity from April ending 5 Jan then FPS then inactive again.
There is still some debate on director / annual scheme and I'm trying to get HMRC to commit to an answer. Key point is if he is drawing regularly and in debit you have an on or before issue.

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Inactivity filing specification is somewhat broken

RebeccaBenneyworth wrote:
I was quoting HMRC tweet but adding that inactivity (as opposed to Nil EPS) was also easy. One delegate paying director in Jan only prompted my comment. Simplest to do inactivity from April ending 5 Jan then FPS then inactive again. There is still some debate on director / annual scheme and I'm trying to get HMRC to commit to an answer. Key point is if he is drawing regularly and in debit you have an on or before issue.

HMRC business rules do not permit the current month to be included in an inactivity forecast when filing an EPS. There is no way of telling HMRC that the *current* month is a nil EPS. This is a design bug, acknowledged by HMRC, which they don't intend to fix before the start of 13/14.

You can't file for advance years, so the ludicrous workround for a single January payment is...

...in April you'd file inactivity from 6th May to 5th Jan

Then in May you'd file a nil EPS from 6 Apr to 5th May

Then you file an FPS for the actual payment during Jan and you must remember also during Jan to file the Feb/Mar inactivity report, or you'll get involved in the confusing reverse-order notifications again because once you've arrived in Feb you can't say that Feb is nil until March.

 

I'd love to be told my understanding of this is wrong.

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Thanks again

Agree it sound like the inactivity report is going to be the way to achieve this.  I'm fortunate that all mine have sufficient credit balances on loan accounts plus availability of divis to cover drawings during the year, so would be a March entry.

I'm unfortunate ? enough to have given up doing payroll for clients years ago (there's only so much excitement I can take) but the swine expect me to know about it!

Time for bed I think.

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By Lee Tee
21st Feb 2013 10:01

Need more info

sorry Rebecca

Where can I find our more about this 'If a director is paid on account of earnings an amount less than LEL then no FPS is necessary. '

 

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no staff paid at or above LEL

"If an employer has no staff paid at or above LEL then no scheme is required, although you may want a scheme to report benefits. File inactivity for the whole year - a single EPS.-Rebbeca 20th Feb"

Sorry - I'm sure AW has discussed this, but I've missed it,

 

under the new RTI - is there still no requirement for a PAYE scheme, if, as in the case of many small shops, there are no employees paid over the LEL threshold.  Do we still get a P46 completed and signed and available for inspection. - I thought under the new RTI P46 were being removed?

If RTI is about information for tax credits, how does it collect information about a person on minumum wage working 16 hours a week - in a business where all employees are below the LEL  and therefore not running a PAYE account

??

 

 

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By DMGbus
21st Feb 2013 13:18

How DWP get information where no RTI reporting...

This is a copy of some text from HMRC webpage guidance, September 2012:

Where an employee earns less than the LEL and the income is not required to be reported under PAYE, the individual will be expected to inform DWP of their earnings. As part of Universal Credit, DWP will have alternative processes to collect information about income that is not reported through RTI.

So, if DWP actually have "alternative processes" to collect the data why do we have to have all this RTI reporting nonesense?

(answer just may be: the introduction RTI increases the opportunities for employers to fall foul of penalties for failing to fulfil reporting obligations.  NB. this information did NOT come from an insider within HMRC who works for a secret [fictional] "penalty yield development" department). 

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22nd Feb 2013 00:03

Thanks Tom

Using the data ranges on HMRC website this is not clear, but in talking to software guys, it seems that the inactivity report is incorrectly set up. Rats!! Agreed with your protocol though.

As far as claimants eaning under LEL with an employer paying all staff below LEL - John Andrews put it well - you wouldn't want to be a claimant in that position....

For many, the director situation boils down like this:

Director draws money from company willy nilly. No credit balance available. Ends up with big debit balance at end of year. This will be cleared by salary and dividend. For salary. payment has already been made, so filing FPS showing £7,000 (say) means that on or before rule is breached. Only solution is to draw a cheque for £7,000 at same time. Result : debit balance no smaller. Any solution needs to be based on payment matching the FPS's filed. Could be annual, could be monthly. BUT you need to pay so that any other draw down is loan and not confused with salary. I hope this is clear - it's been a bt of a long day!! I'll read it again tomorrow afternoon (I think that might be THIS afternoon actually) to check it makes sense.

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Broken inactivity Report

RebeccaBenneyworth wrote:

Using the data ranges on HMRC website this is not clear, but in talking to software guys, it seems that the inactivity report is incorrectly set up. Rats!! Agreed with your protocol though.

My suggested protocol would work, but it is far too confusing a concept for our typical small business non-IT end-users and I couldn't possibly recommend that anyone work that way however systems literate they are. The design has accidental error built into it as its principal feature.

Until HMRC fixes the design bug in multi-period inactivity reporting they should stop touting it as a solution to the infrequently paid director problem. In fact they should stop mentioning it at all when it is so flawed a solution. Until that bug is fixed we won't even implement it in our product, because the risk of users misunderstanding what/when/why they should file is far too high. Even if they understood what to do they wouldn't understand that the problem was HMRC's fault not ours (based on our experience) , and we'd get endless complaints about the "error in our software".

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22nd Feb 2013 03:14

Mr Willy Nilly & RTI

Am I correct in thinking that if (to pick a easy number) Mr Nilly makes an RTI submission of, say, £600 gross pay every month - but in fact the only 'pay' he is being paid is the fairly random amounts he draws from the company (or spends with the company debit card) just when the mood takes him - then there will be no problem in relation to the £7,200 journal credit of 'salary' made to his DLA when the annual accounts are done?

Or is it the case that, even in this situation, there actually needs to be a bank payment each month which is identifiably Mr Nilly's salary payment (even if he pays it straight back into the company again).

I appreciate that doing an RTI submission every month will be a pain in the proverbial, but if that is the best way to keep Mr Nilly out of bother with HMRC . . .

RM

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22nd Feb 2013 07:32

Mr Willy Nilly

I know Mr Willy Nilly very well too!

Does RTI make no allowance for the possibility of CASH payments?

 

RG

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claimants eaning under LEL

"RebeccaBenneyworth wrote:As far as claimants eaning under LEL with an employer paying all staff below LEL - John Andrews put it well - you wouldn't want to be a claimant in that position...."

Sorry - but please explain what this means - Who's the claimant and why wouldn't they want to be in that position -?

Many small shops employ part timers simply to keep them below the LEL and keep themselves out of the PAYE system

 

 

 

 

 

 

 

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25th Feb 2013 12:31

@jean reeve

jean reeve wrote:

"RebeccaBenneyworth wrote:As far as claimants eaning under LEL with an employer paying all staff below LEL - John Andrews put it well - you wouldn't want to be a claimant in that position...."

Sorry - but please explain what this means - Who's the claimant and why wouldn't they want to be in that position -?

Many small shops employ part timers simply to keep them below the LEL and keep themselves out of the PAYE system

 

The claimant is the employee who is working and claiming tax credits.  You wouldn't want to be in that position because the shop won't have to run a payroll if everyone is paid below the LEL so the info regarding their pay won't be automatically provided to HMRC via RTI which is likely to make things a bit confusing.  I can see a lot of people in this position being overpaid if HMRC automatically assume that no RTI info means no employment income and then being asked to repay at a later date.

 

 

 

 

 

 

 

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25th Feb 2013 12:25

I have more Mr Willy Nillys than Smiths!

Hi All,

This is fun isn't it - isn't RTI supposed to make all our lives easier?

So based on Mr Willy Nilly (Mr WN) taking money as and when he pleases, sometimes being owed money by the company (e.g. if we've just issued a didvi) and sometimes owing money to the company, if a payroll is run when his DLA is a dedit balance, is crediting the DLA not considered the actual "payment" with all other withdrawals being loans?

Do we actually have to make the payment to Mr WN by moving the money out of the bank and into his bank (or hand if it's cash) and then either getting him to transfer it back or just paying it back in if it's cash.

I can't wait to explain that one to all my Mr WNs!  Maybe the key is to keep petty cash of just over his monthly salary (lets say around £1250 for a husband and wife) and then "pay" the petty cash each month (they can sign a receipt to say they received it) which they can then pay immediately back to clear part of their DLA and each month it just, in effect, comes out of and goes back into the petty cash box.  I guess as long as the cash balance is correct when you have an inspection and you have all the receipts to match the payslips/FPS submissions this should be OK??  What do you think?

Many thanks

BG

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By BK
25th Feb 2013 12:29

Plain english please

Is there any chance that people could use plain english with clear and complete factual statements rather than clever anecdotes and the 'in' speak!  Am I right in believing that Directors and other employees being paid below LEL means that there is no RTI requirement including no requirement to report 'inactivity'?  A simple yes or no without clever commets about HMRC incompetence or whether one might not want to make claims will suffice :)

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Hopefully this is plain enough

BK wrote:

Is there any chance that people could use plain english with clear and complete factual statements rather than clever anecdotes and the 'in' speak!  Am I right in believing that Directors and other employees being paid below LEL means that there is no RTI requirement including no requirement to report 'inactivity'?  A simple yes or no without clever commets about HMRC incompetence or whether one might not want to make claims will suffice :)

Company with PAYE scheme

If the company has a PAYE scheme then all employee payments must be reported, whether their payments are above or below LEL. If there are no payments in any PAYE month and a PAYE scheme exists an inactivity EPS must be filed.

Company without PAYE scheme

If the company doesn't have a PAYE scheme then there is no need to file any kind of RTI report, nor is it even possible to to do.

When must a company have a PAYE scheme?

A company must start a PAYE scheme the moment (a) any employee earns above the LEL in any pay period, or (b) any employee ticks P46 box C or refuses to tick any P46 box. (a P46 must be held on file for all employees with either Box A or B ticked for the company to remain outside PAYE scheme)

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25th Feb 2013 13:07

A few additions

Universal credit claimants

There will be a requirement for universal credit claimants to report btheir income each moonth if the employer is no in RTI. The draft Regs are available on the revenuebenefits.org website.

Directors

It has been held at previous appeal some years ago that payment is made when the money is withdrawn from the company where there is a debit balance. So in order to make RTI filing (assuming that there is a requirement to do so - director paid at or above LEL) you need to be able to (a) state the date of payment, and (b) file on or before payment is made. Hence in my view you need to make a decision about both running the payroll and drawing off the funds so that all of this information ties up. If the loan account is in credit the crediting the salary into the loan account (before it is physically withdrawn) counts as payment for PAYE purposes, so putting the salary to the credit of the loan account allows you to do a single payroll run and single journal entry for salary - provided the director has a credit balance, A note that any excess amounts drawn are to be treated as a loan would lock down the position regarding additional payments.

Where the account is in debit, then the earliest thing that happens is that money is drawn so in my view you need to make actual payments to match the salary reported through RTI.

Need for a scheme

Where no employees including directors are paid equal to or above LEL there is no need for a PAYE scheme. Thus no scheme = no reporting. If you have a scheme because you need to make P11D's etc at the end of the year then the answer at present does not seem to be straight forward. I'm just trying to get some more feedback on this from HMRC and will come back on with a clearer answer. 

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25th Feb 2013 13:41

Debit DLA and salary payments

RebeccaBenneyworth wrote:

Where the account is in debit, then the earliest thing that happens is that money is drawn so in my view you need to make actual payments to match the salary reported through RTI.

Hi Rebecca,

so can I just check I've understood - the director can withdraw money as and when and this can be a drawdown of a loan as long as when the salary is paid an actual payment of the correct net salary amount is actually made so as to avoid any confusion with the loan amounts taken at other times.  If the director wished he can then repay this amount to the company to reduce his outstanding loan.  So if the company held enough petty cash to cover it could the director be paid in cash and then give the company cash back as repayment of part of his outstanding loan?  If the correct entries were made in the accounts and there were receipts each month signed by the director to show that he received the cash (and then repaid it) do you think this would be sufficient?

Thanks

BG

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25th Feb 2013 13:59

RTI - Payments below LEL

"You need to include the details of all employees you pay, including those who earn below the NICs Lower Earnings Limit (LEL), for example students."

This is a quote from HMRC's information on RTI.

There appears to be no need to register as an employer unless you have an employee paid above the LEL.

I am confused by the apparent mismatch.  What am I missing?

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By BK
25th Feb 2013 14:25

RTI - Payments below LEL

My take on this - after speaking with HMRC - is that if all employees are paid below the LEL (including Directors using 'annual cumulative') then there is no requirement to register as an employer.  However, if even one employee is paid at or above LEL then you must register as an employer and provide details for ALL employees under the RTI scheme.

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25th Feb 2013 17:30

Something is not OK

"If you have a PAYE scheme in a ltd company RTI applies".  But how can you not have a PAYE scheme in a ltd company unless the director's claim no expenses?

I know that many accountants and their clients have turned a blind eye when expenses claimed = expenses incurred and not lodged a P11dx.  Relating back to the comment above a Penalties I do wonder if this may be the time HMRC start dishing out penalties for non-compliance - someone has to pay for RTI!

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25th Feb 2013 18:02

'Loan' or advance salary payment?

I think the Mr Willy Nillys will come to grief, (or at least a £1,200 fine) with RTI.

Assuming his loan account is not in credit, if he draws money out that is in reality an advance of salary, can we say that is a loan?  He never intends to actually repay it as such, so surely it is just an advance on salary and should be returned under RTI.

If that is not the case, then where does it stop?  Eleven monthly loans and one 'bonus' payment?

Under RTI Mr WN may find Wonga.com is a cheaper way to have 'payday loans'!

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26th Feb 2013 01:02

Payroll

I agree with Paul Johnston. You should be running a payroll if the company provides expenses and you need a dispensation.

And if you charge one accountancy fee which includes a personal tax return, there is also a benefit in kind. The Revenue have dropped interest on this point in recent years but it is still the case. Payroll needed.

But I really dont understand the issue. Once the payroll is set up (say moneysoft), I would estimate it takes about one hour every month to go in and press send on all your director clients. Just run a monthly salary instead of a yearly salary. You will spend more time working out how to bypass the procedures rather than just getting on and running the payroll.

Also if you client has a monthly salary they can pay a direct debit which tallies with the payroll rather than various credits on the account and a question mark over whether these should be deemed as salary.

 

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Has my question added to human happiness & understanding?

Blimey......what's ironic is that I passed all my payroll/PAYE work to another accountant nearly three years ago, so was asking for me & my wife's business where we draw the typical base salary.

With regard to not needing a payroll if pay is below LEL, hasn't that always been the case?

Then, with regard to director's/employee expenses, once you have a dispensation and stick to it, surely, if there's no other reason to have a scheme, this is not reason enough to maintain one?  All you'd do is start one up if you ever got a company car or, as Peter says, use company money to pay a personal accountant's bill (thought that went out with the 80s?).

I tend to agree with others that, having to press a button or two (or click a mouse) 12 times a year, is not worth getting upset about especially if FreeAgent do, in fact, get RTI compliance up & running in time, so I don't have to login to HMRC every month.

Thanks to all.

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By Vince54
02nd Mar 2013 00:37

Annual Schemes

The following guidance from HMRC may help.  It was provided to CIPP but why it isn't on HMRC's website (well I can't find it on there) or made more widely available for accountants who really need to know this ...

Annual schemes:

 

Q: Will there now be two alternative ways of notifying HMRC that a PAYE scheme is annual, i.e.:

either using the system to register as an annual payer/filer described using the link in your email dated 6 December below or by sending in a ‘no payment due/period of activity EPS’ as described in my email below dated 9 January,or will employers still always need to register as an annual scheme using the former process, which by so doing obviates the need to submit ‘no payment due/period of inactivity’ EPSs?

 

A: 1) As now, annual schemes should be registered with HMRC: http://www.hmrc.gov.uk/paye/file-or-pay/payments/deadlines.htm.  We will be including this information in the RTI guidance for April.  Where an employer operates an annual scheme – i.e. only one payment made to the employee and one payment due to HMRC a nil EPS is not required each month.

 

2) If the employer only takes one payment per year and does not register as an annual scheme, they will be required to submit a NIL EPS for each period they are not paid and an FPS for the period where they do take earnings.

 

3) However, your question refers to employers/owner directors who take a set amount each month and currently only report annually. These are not annual schemes and will be required to report their earnings via an FPS on or before payment (in this example – for each month). An EPS is not required if the FPS indicates no payment due to HMRC as the data will be extracted from the FPS.  An EPS is only required if no payments have been made to employees (so no FPS) and therefore no payment is due to HMRC and/or the employer wishes to claim adjustments to the amount owed to HMRC.

 

4) If an employer pays their employees every 2, 3, 4, 5, 6, etc month we expect an FPS for each month payment is made and a nil EPS to be sent for each of the intervening months when no payment is made: http://www.hmrc.gov.uk/payerti/reporting/what-to-report.htm#7.

 

Q:  Will one be able to use HMRC’s Basic PAYE Tool to do what is envisaged, i.e. submit ‘no payment due/period of inactivity’ EPS in advance (i) in the same tax year, and (ii) in a previous tax year relating to the next tax year, e.g. submit EPS in March 2014 in covering 11 months 6 April 2014 to 5 March 2015? 

 

A: 1) Employers (or their agent) are not required to submit a nil EPS return for the 11 months where payment/earnings are not taken.  An FPS will be required for the month when payment/earnings are taken. The FPS should be submitted on or before payment of earnings.

 

2) Where an employer takes a regular amount each month, they could submit 11 FPS returns (April – Feb) in advance in April and submit the final return in March. We would not recommend that they submit all 12 returns at the same time in April. From April 2014, we will be able to accept returns submitted before the beginning of the tax year. The exact detail has still to be confirmed, but we expect to be able to receive submissions during March, providing the employer or their agent is using the schema for the next tax year. However, I expect that the BPT will operate on a strict tax year basis as now, so the BPT for 2014-15 would not be released until April 2014.

 

3)  Where an employer takes a regular amount, say every 3 months, they could submit FPS returns for each of the planned paydays and EPS returns for each of the intervening “nil” paydays (I am waiting confirmation of this and will let you know if the position changes). As at A:2) the submissions could be made in advance.

 

Q:  Where it is decided to pay employees (e.g. directors of owner-managed companies) a regular salary for tax months 6 April to 5 March with a possibly different payment in the tax month 6 March to 5 April, will employers/agents be able to submit in March of the previous tax year 11 FPSs in advance covering the next tax year, e.g., in March 2014 submit FPS for final payment made in March 2014 (and that FPS could also include the end of year declarations) and at the same time submit 11 FPSs for the following year covering each of the tax months 6 April 2014 to 5 March 2015 showing forthcoming regular monthly payments of salary? 

 

A: yes, HMRC can accept the final FPS for the March earnings and the 11 FPS for the following year, providing their payroll software is using the correct schema for the relevant tax years. 

 

Q:  If ‘yes’, will it be possible to use HMRC’s BPT to do this?   If small payrolls comprising only one or two employees can be administered once per year then compliance burdens for businesses and hence costs will be minimised.

 

A:  I am not able to confirm that BPT users will be able to submit the return for March of one tax year at the same time as submitting FPS returns for the next tax year. The BPT is currently released in April for the current tax year and I expect this to continue because the BPT is designed for micro employers with simple payroll and feedback suggests that it is easier for them if the updated BPT is released at the time they need to use it.  The employer or their agent would therefore need to submit month 12 in tax year A and submit the 11 FPS returns for tax year B on or after 6th April. (But this may change – one never knows!)

 

However these answers do come with a word of caution from HMRC

 

HMRC does not recommend that employers submit returns for the full year in advance

 

If an employer or their payroll service provider submits returns in advance and the amount changes they will have to submit corrections and amendments for the period of change and all the future periods where the FPS has been submitted. E.g. if they thought they were going to take £100 per month and submitted 11 FPS returns, then in month 4 decided to take only £50 they would have to submit amendments/corrections fro month 4, month 5,6,7,8,9,10 & 11

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