I am sure other firms have some clients for whom a P11d is required although no salary is paid. We have just found out, after submitting a nil PAYE return, that the scheme was in fact closed in April 2010, apparantly by HMRC and without informing us or the client. Apparantly, that is too long ago for the scheme to be simply reopened, and they have suggested we apply for a new scheme!
We have submitted a 11/12 P11d (for a director, with just a subscription on it), and this went through OK, although God knows how HMRC will allocate it down the line.
Just interested whether other people have been in the same boat.
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I had a situation where there was no PAYE reference in existence but P11D's were required. In that instance HMRC issued a PAYE reference after I had sent the P11D's in. That was about 3 years ago now though!
I have had the same problem (HMRC spontaneously closing active schemes and not telling anyone).
So far I have taken the line that as the problem has been created by HMRC's error in closing a live scheme without any request to do so, it is for HMRC to correct the error or live with the consequences.