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HMRC forms: Frustration and confusion

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25th Jun 2015
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The future of UK tax is online – or so HMRC would like us to believe. All new HMRC forms must be completed online, and many of the old paper forms are being replaced with new online versions

Apparently there is a HMRC working group which is responsible for producing the new HMRC forms, but there is no evidence that this group thinks about the needs of tax agents when designing those new forms.

This lack of “customer input” (tax agents are HMRC’s customers as much as taxpayers), is creating problems for accountants who are paid to deal with HMRC forms for their clients. The issues I have identified so far include:        

Hidden pages

Most of the new interactive PDF forms only allow you to move forward to the next page of the form after all the required information is completed on the earlier page. This means the form can’t been viewed in its entirety before the completion process begins, and you don’t know what information will be requested on a later page. A typical example is form L2P for reclaiming s 455 tax paid on loans to participators.    

The work around is to complete the form with dummy data and screen print each page for future reference.

Secret address

If you manage to reach the last page of the new online form, you are often faced with an instruction to print the form, sign it and send the signed hard copy to HMRC. However, the exact address to which the form must be sent remains a mystery. Examples include the R40 and R43 forms.

The necessary addresses for submitting form R40 are given on the webpage where the forms are found, but no on the actual form itself!

Banned attachments

Occasionaly HMRC needs further information to be supplied in order to action the taxpayer’s request. We know that HMRC will ask for the information but there is no box on the form to submit it, and no means to attach the relevant document to the online submission of the form. An example of this is the online application for VAT registration.

Boxes too small

The HMRC forms design group obviously has a brief to consider only UK reference numbers when deciding how many digits each data box can cope with. Where a taxpayer has an overseas bank account, or perhaps a foreign registered company, the reference number may well be too long to fit in the designated box. Hence the form completion fails.

Incompatible software

Sometimes HMRC asks the taxpayer (usually an employer) to submit a large volume of data in one go, such as for a section 16 return. In those cases HMRC will generally provide a template spreadsheet for the employer to use.

That works well when the employer can easily import the template and complete it using their standard software. Most large organisations use Microsoft software, so it makes sense that the section 16 template is a MS Excel spreadsheet.

So why is the “other employment related securities: end of year return template” in an OpenDocument format rather than MS Excel? The OpenDocument format is not necessarily compatible with Excel and it’s just another thing to frustrate the employer and their tax agent.   

That particular spreadsheet template replaces the old Form 42, which in a straw-poll of tax advisers was voted the most hated HMRC form. Is it top of your “most hated” list?     

Let me know which form (or template) is the worst HMRC form and why, by posting below. I will send a copy of Bloomsbury’s Tax Rates and Tables 2015/16 to the person with the best reason to hate a particular HMRC form.

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Replies (42)

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By 0242736
25th Jun 2015 10:36

End of Year Expenses and Benefits Forms 2014-15 - won't submit

Been trying to get this to submit and print P11d's after entering all info and it won't work. I've found a thread in here from two years ago with exactly the same issues, so seems they've not fixed it after this amount of time. Very frustrating as am now going to have to re-input all info and submit through the website directly.

Unless there is a fix, I've not found yet?

 

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By jon_griffey
25th Jun 2015 11:20

I claim my prize!

Form 42 takes the prize by a mile. For 2014/15 Form 42 MUST be filed online. There is no paper alternative.

Let's take a simple example whereby some shares change hands between 2 directors in a small company. Typically the company may make minimal profit, if any, and have minimal assets and so there is no value changing hands and no tax whatsoever at stake. Nevertheless this is an event reportable on Form 42.

Firstly, the company never pays salaries or provides benefits and so has no PAYE scheme. In order to file Form 42 a scheme must be registered. Having registered the scheme, the client needs to register with HMRC on the Gateway and enrol for PAYE services.

Once enrolled for PAYE services the company needs to register an employment related securities scheme. Note that the agent cannot do this from their side.

The agent then needs to apply for an authorisation code for ERS, and also for PAYE in order to deal with RTI.  Paper form FBI2 will need to be filed.

To complete the return, the agent first needs to download and install Libreoffice on their PC. Software that they don't want cluttering their system. Having got to grips with this unfamiliar software and completed the return, it needs to be sent to the client for approval. How does a client approve a spreadsheet? It will mean printing off the report and sending it to the client for signature or e-approval etc. It is difficult to print off as the sheet has endless columns and so needs to span several pages.

The client having approved the return, the agent then uploads it to HMRC. HMRC will likely do nothing with this information as there is no tax at stake.

However it doesn't end there. The client is now 'in the system' and so will continue to be pestered for returns in future years and have to make RTI filings ad infinitum to keep the scheme open. Does the client want to pay for all this pointless admin? Thought not. Will the cowboy firm down the road that undercuts me even bother complying with this, like with P11D's? Thought not.

The process is so unwieldy that it positively encourages non-compliance.  Something must be done. There needs to be some sort of simplified regime for plain vanilla small companies that are just reporting share movements - which must be 90%+ of returns.

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Replying to DJKL:
Head of woman
By Rebecca Cave
26th Jun 2015 09:21

No PAYE scheme no 'form 42' needed

 The latest ERS bulletin ( number 20: July 2015) says an annual return for the scheme is not needed if:

neither the company, nor any other company in the same group or under the same ownership, is registered for PAYEthe arrangements are not tax-advantaged schemes (that is, not Share Incentive Plan, Save As You Earn, Company Share Option Plan or Enterprise Management Incentive schemes)the company has no obligations to operate PAYE in respect of the reportable eventthe company has no obligation to operate PAYE in respect of anything else it does.

So Jon-Griffey's example above would not apply. However, I agree that the OpenDocument spreadsheet formerly known as form 42 is the worst "form" HMRC have ever produced, and Jon-Griiffey deserves the prize.

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Replying to DJKL:
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By tlang98413
29th Jun 2015 13:37

Form 42 practicalities

We have had similar issues on this and have lost masses of time for cases where there are no tax implications.

I wonder whether in future it would be possible to submit the returns in a similar way to the ATED returns i.e. without having to login first, I know that this means the information has to be entered but it has to be in the current format anyway.  This will mean that agent authorisations do not need to be activated before we can submit the return.

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By Eyrie
25th Jun 2015 11:28

What is the point?

I get frustrated at the fact that the forms have to be completed on screen in the first place, yet they still have to be printed, signed and submitted by post.

It's much easier to be able to ask new clients in particular to complete and sign the form during a meeting than it is to complete a dummy form so that I know what information is required, then note that information during the meeting, type it in afterwards and finally send the client the form for signature and return.

 

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ghm
By TaxTeddy
25th Jun 2015 13:01

Some very good points here

And I suspect this is the tip of the iceberg.

Going forward, this will get worse as long at the policy wonks at HMRC are disconnected from those of us who 'get our hands dirty' with the forms. Working Together should have been the forum for the profession to engage with HMRC, iron out the wrinkles and take these processes forward. None of us are opposed to e-forms as long at the process works.

But I gave up going to WT meeting when it became clear it was just a PR stunt with no real dialogue.

The time has come for a real forum - HMRC and small practitioners. Come on AWeb - let's get HMRC to the table.

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By Duhamel
25th Jun 2015 13:11

Form 42
I second the Form 42 point, Jon layed out the reasons far better than I could and in greater detail. I agree with every word.

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By nogammonsinanundoubledgame
25th Jun 2015 13:19

Acknowledgements of submission

Some forms, generally statutory returns, result in an email acknowledgement.  The email acknowledgement may identify the taxpayer's reference, but will not state the taxpayer's name or agent's reference despite that an agent's reference is entered in the online record and the form is being submitted by the agent.  There may be security reasons for leaving off the taxpayer's name.  But agent ref??

Worse, more generally, forms that are submitted as "structured emails" from gov.uk website, will generally result in a screen display confirming successful submission.  In these cases there is NOTHING to indicate the client, or date and time of submission, no tax reference and certainly no client reference, in the acknowledgement page, which is the only evidence of submission.

Sometimes you get a prompt to print the structured email before submission.  Better make sure that you do, because it is your last chance to get a record of what was submitted, and you are not always prompted.

With kind regards

Clint Westwood

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By djtax
25th Jun 2015 16:40

Been there, done that - but HMRC still do not listen

Your point on 'hidden pages' was specifically drawn to HMRC attention last year at our (now defunct?) local Working Together group. Also it got mentioned at an HMRC online services regional workshop with practitioners on 30/3/15 held at their London HQ. Proves beyond all doubt that they do not listen to us.

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By justsotax
25th Jun 2015 16:47

Jon does indeed

win the prize...I cannot believe that someone would make use of technology in such a way that it acts more like anti virus software not allowing you to gain access rather than a helpful quick and issue way to report share transfer events.  At this late stage I have only just realised that not only does the client need to register the ERS scheme but that its going take at least a week to get the authorisation code - a best it looks like at an appeal against the penalty. 

 

I did speak to someone at the share scheme office - they tried to suggest that the OTS had come up with the ridiculous procedure...who cares - but I wonder how many ERS forms will not be submitted at all.... 

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By hedleyg
26th Jun 2015 10:20

It could have been so easy - a technical response

When it comes to computer systems, HMRC are bogged down with legacy systems and show a complete lack of vision.

It could have all been done so easily.

All HMRC forms should be in the form of writeable PDFs (with user guides as PDFs).
These forms could be filled in online or OFFLINE by their customers.
Each box on the form would require a unique reference (set by HMRC).
Each form sent to HMRC would require the form to be renamed with a date, YYYYMMDD, and a unique customer reference.

Then send the forms as attachments to Emails with the 'receipt required' flag set and copies to agents/clients. The HMRC response should be an Email 'reply to all' with a checksum for each file (sha1sum, md5sum, etc) so the forms are fixed and cannot be altered.
HMRC, in their own time, could do a preliminary verification check on each form offline, and, in the case of errors, send back a list of errors to the customer to be corrected. If the agent/client discover an error/omission of their own, simply resend the form.

This would work with ANY computer system, and be immune to power failures, ISPs down, not overload HMRC online computers, etc..

The current online processes require users to have a computer system, specific system software, internet access, and a lot of spare time. When the current online systems need altering, the complete process needs to be altered by specialists/consultants/contractors and thoroughly tested - very costly and normally late.

What could have been easier than a new PDF form for the Transferrable Marriage Allowance - job done.

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By justsotax
26th Jun 2015 10:19

@taxwriter...

agreed...however being issued on the 24th June (merely 2 weeks before the deadline) realistically anyone who had fully understood the system would have already commenced this most ridiculous procedure...hardly a glowing example of proactive thinking... 

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By jon_griffey
26th Jun 2015 10:38

Good news - but a bit late in the day!

That is indeed good news. But why does it take HMRC until 24 June 2015 to make this announcement for returns to be filed on 6 July? If you hadn't applied for a scheme by then you would miss the deadline anyway.

However that only alleviates the problem for companies without a PAYE scheme. For the typical client with a scheme, they still have to go through the rest of the performance.

What they need to do is extend this concession to remove the first and fourth condition so returns are not needed when: -

- the arrangements are not tax-advantaged schemes (that is, not Share Incentive Plan, Save As You Earn, Company Share Option Plan or Enterprise Management Incentive schemes)

- the company has no obligations to operate PAYE in respect of the reportable event.

I look forward to receiving my prize!  :-)

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By SteveHa
26th Jun 2015 11:28

ODF

It's not that the ODF format is not compatible with Excel, it's that Excel is not compatible with ODF, which is astounding when you consider MS were party to the creation of ODF.

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By dmmarler
29th Jun 2015 12:05

This should be compulsory reading for Mr Osborne

I suspect the civil servants, et al keep all these headaches away from Mr Osborne and the MPs generally - and then MPs are surprised when everyone continues to complain about red tape!  These new processes are causing everyone too much work, are difficult to use, and are keeping an army of civil servants and IT guys in business. (In their present form the Working Together Groups have not worked, and should be disbanded as they are a waste of everyone's time and money.)

 

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By Geoff123
29th Jun 2015 12:09

Online forms

Would it not be better if we all reverted back to Papyrus Scrolls and submitted them instead

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Replying to Manchester_man:
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By leon0001
13th Jul 2015 12:11

Papyrus?

I would be happy with carved stone tablets if you could guarantee that they would be dealt with promptly by competent HMRC staff. After all it takes them over 3 months to answer a letter

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By johnjenkins
29th Jun 2015 12:18

Why oh why

do not HMRC let us do all admin work? and them just investigate and collect.

Let us consider the fraud problem, which is HMRC 's normal why of saying "no thanks". If we are actually doing the fraud then we are easliy captured. So 99.99% of us won't do it. Maybe that £45M earmarked for call centres should be spent on Agent strategy.

Great article though.

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By trinag24
29th Jun 2015 12:22

Screaming at my workstation in frustration


Form 42 has nothing on the "let property campaign disclosure form".

 

Not only is it of the type whereby you can't move on until all boxes on a page have been completed but it is also incredibly rage making when on the letting income liabilities page when you click on the help icon which brings up a link to the online penalty and interest calculator to enable you to calculate the interest and penalties due, once you click the link instead of opening in a new window it sends you to the calculator directly.

 

YOU LOSE EVERY ****** THING!!!

Start again :-(

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By Ian McTernan CTA
29th Jun 2015 12:50

Let property disclosure

I'm voting for trinag24's example, having gone through the same thing myself- there is nothing more frustrating than a form that disappears when you go to the calculator for an entry you need to finish the form.

Maybe if they had a group of agents to test these things and point out the obvious before they publish them we wouldn't have these issues- but then they don't really want anyone to have an agents anyway, life would be much more simple for HMRC if we didn't exist and they could just say 'it's that much, pay it or else' without anyone able to point out the errors.

 

 

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By AndrewV12
29th Jun 2015 13:20

HMRC prefer on line filing

A few of my clients like to prepare their own tax returns (I prepare the Ltd Co Accounts) most prefer to file on paper returns however in spite of filing paper returns for many years, once one return is filed on line thats it, paper returns are no longer automatically issued to clients.  

 

It gets me a little extra work, as clients want their Self Assessment tax returns filed without delay (me filing them on line).  

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By leon0001
29th Jun 2015 13:26

It just gets worse and worse....

When I tell clients about this kind of time consuming change they just don't believe me.

The worst thing is not being able to get confirmation of what you actually transmitted and when it was received.

Why don't they just give us complete access to their systems and get rid of the "form" stage altogether.

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By David Gordon FCCA
29th Jun 2015 14:38

Long Long ago

 

 Long ago, when I was a keen young audit clerk;-

 I used to attend the audit of a mega-company which constructed vast prefabricated buildings to order.

 The company had a special department comprising a team of older experienced engineers.

 After the designer and the customer had agreed on the almost-final design, this was passed to this special department. The standing instructions were to rationalise the design.

 So for example, if the design used twenty sizes of nuts and bolts, these experienced fellows would work out how to reduce that number to ten or less. They never failed to provide an rational improvement on the designer's wizz-bang. Not big stuff, but things which made the end result work better. for example where to put the toilets, or the canteen. (tea flavoured with deisel fumes is not pleasant)

 If only HMRC would use such a department.

 

 

 

 

 

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By johnjenkins
29th Jun 2015 14:56

Like the idea

David but it can't work. HMRC and the Accounting world think totally differently so there is no real common ground to work with. You can see what happens. WT, all but extinct. Agent Strategy, not long before the plug is pulled. OTS, new mandate - uh!!!!!!!!!!! 

Anything that tries to bind us together other than PR falls apart and it is from HMRC's end. So why do we actually expect anything else but crap from them. They are working in an IT world which they haven't got a clue about. Can you imagine what it must be like for a computer buff working in HMRC as an officer not being able to use e-mails. I bet half (maybe more) the staff are thinking "what bunch of pratts set this up". 

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By chatman
29th Jun 2015 15:02

Online VAT Agent Authorisation

Despite telling you and the client that electronic authorisation is valid for all agent communications, the telephone operators, 90% of the time, will not accept it.

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By David Gordon FCCA
29th Jun 2015 15:24

John jenkins - another true story

 

 An acquaintance of mine was before his retirement a senior IT manager with the company that put in the HMRC system.

 His informed opinion was it was crap, his words.

 One day, he whispers in my ear that he has been authorised to take on 300 extra staff in order to get the system to work.

 About the same time another acquaintance, now RIP, was charged with designing and installing a system involving approx 900 computers, one for each pupil plus extras, into a well know public school.

God bless him, when they switched on to live, it worked first time without a hitch.

 I promise both the above tales are true, the difference is, in the second case both the designer and the end user worked together, and knew and understood what was needed. Just as important, there was no politics involved.

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Should Be Working ... not playing with the car
By should_be_working
29th Jun 2015 15:30

The humble SA1

Or, in fact, any complete-on-screen pdf form ... works fine unless you're using Firefox; one of the more popular browsers, whereupon it hides beyond reach signficant elements like the address or NI number fields. So, for the first time in donkeys years I had to root around on my system to find Internet Explorer (a.k.a the best browser for downloading other browsers).

All in all a small thing, but aren't developers supposed to test this sort of stuff on different browsers and popular OSs?

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Replying to Tax Dragon:
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By graemep
22nd Jul 2015 08:38

Not sure you need IE

should_be_working, Have you tried opening it in an external PDF reader (probably Acrobat Reader is best in this case) from Firefox, instead of using Firefox's built in reader. There are settings to make this the default.

jon_griffey, Excel (and the rest of MS Office) can save to Open Document format. It is built in, in recent versions, but you need to install a plugin for older versions. You can also use Google Docs to convert between the two (upload the Excel file, and download it as Open Document). There is also a lot of other software that supports Open Document: https://en.wikipedia.org/wiki/OpenDocument#Software so there is no need for Libre Office if you do not want to install it.

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By prue.stopford
29th Jun 2015 18:33

Thank God I've retired...

... and am about to submit my SA Tax Return ON PAPER (first time for donkeys' years) just because I still can! My sincere condolences to you all.

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By ds
29th Jun 2015 20:06

What is the Issue here ?

The accountants on here complaining should be praising HMRC for providing them with extra work, it is the clients who are asked to pay for it who should be kicking up a fuss.

 

Is it a LEGAL requirement that information sent to the Revenue has to be provided in the manner they say, ie via the internet?  I would suggest paying the correct and legal tax is the issue, how it is presented is another matter. If their systems are so poor, then create your own form and send it to them with a short note explaining why. If it ends up in court, tell the judge all the information they need has been provided and the tax already paid. Refuse to pay any penalties as they are not  LEGAL.

 

What is the problem? How has the Law been broken? What crime has been committed. Until the HMRC are prepared to pay a reasonable hourly rate to those who have to work with their badly thought out systems, then I suggest this is an approach we all take. They may well then concentrate their worldy minds on this problem and act in a professional manner.

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By Myshkin
29th Jun 2015 20:22

CT return
The worst one I ever come across is HMRC's on line Corporation Tax return where if you don't enter a figure in the share capital box you can't move on. Thus tens of thousands of companies limited by guarantee need to lie and say they have £1 share capital. Useless for lodging jointly at Companies House though

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By irbrbbas
29th Jun 2015 23:48

HMRC v IT

Why use IT to download a form and be unable to use IT to submit it? So much for them wanting "online" filing. Crap is too good an expression for the cowboys who call themselves HMRC.

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By Springfield
30th Jun 2015 10:21

Feedback to HMRC

Can I suggest that AccountingWEB print this entire thread at the end of today and then post it to the head of HMRC (copied to the appropriate Select Committee) and ask for their comments - within 30 days of course?

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Replying to GlobalTax:
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By dmmarler
30th Jun 2015 12:27

Not just feedback to HMRC

Please send a copy o this thread to your respective Members of Parliament so they can start to understand where things are going wrong!

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Replying to GlobalTax:
Head of woman
By Rebecca Cave
02nd Jul 2015 10:44

feedback to HMRC / GOV.UK

I asked Tax Faculty how to get HMRC to pay attention to the problems with various forms. Thier reaction is:

We have already raised the problems with the forms with HMRC and will be pursuing it further

The best way to get improvements to each page is to send a comment through the link at the bottom of the page - Is there anything wrong with this page?

The message gets straight back to the team of designers who will look to make changes

The more who post the more they realise it is an issue which needs to be addressed

Working Together anyone?

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By Gone Sailing
30th Jun 2015 22:15

HMRC Emails
Don't get me wrong - I love emails - they have so many valuable uses - most of my client communication is by email.
But I would be extremely reluctant to send any but the most straightforward to HMRC.
There is an art to keeping an email clear and short.

Ever tried resolving a technical problem by email? Back and forth / forth and back. Now I'm email replying to the 5th different person, who hasn't even bothered to read what the others have said.

SA helpline is great, they usually answer within a minute, and nothing beats talking. Also, big surprise, PAYE Employers Helpline picked up straight away this week the magic "agent" word.

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By Gone Sailing
30th Jun 2015 22:18

64-8
I still send in a paper 64-8.
The SA online authorisation may gain authorisation for online SA filing, but it does not (please correct me if I am wrong) authorise HMRC to talk to me.

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Replying to Lisa Edney:
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By chatman
01st Jul 2015 08:29

Electronic VAT agent authorisation is equivalent to 64-8

Gone Sailing wrote:
The SA online authorisation may gain authorisation for online SA filing, but it does not (please correct me if I am wrong) authorise HMRC to talk to me.

It does authorise HMRC to talk to you. The only problem is that some (not all) HMC&E staff do not know that. The ones that do ask you for your Government Gateway user ID and locate the authorisation that way. Unfortunately most don't. 

The problem this causes for HMRC is that agents feel compelled to submit paper 64-8s. Once you are completing a 64-8, and given that electronic agent authorisation codes sometimes (not that frequently these days) fail to arrive, it makes sense to complete the sections for all taxes. Presumably this creates additional work for HMRC processing the 64-8 for all the other taxes in addition to VAT. If only VAT call-centre operatives were taught to accept the on-line authorisation, they would save themselves all this work.

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By Gone Sailing
30th Jun 2015 22:22

PAYE / RTI / FPS
I filed a new client's FPS this week, I did not use the initial authorisation process, they are not on my online HMRC agency list.
I just used my online agency ID and the client's PAYE refs and I am assured it was processed (was using a well known software).
What can possibly go wrong?

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By coolmanwithbeard
01st Jul 2015 13:39

Extra information

It's the stuff you may once have added in a separate sheet or covering letter - so I recently wanted to set up a dispensation for a client who has this tax year discovered leaving the office and going on business trips. The online P11DX has no where to ask for it to be back dated to the start of the tax year (even though the notes say they might) and no free hand field to add any comments. Fortunately there is still a paper form that I was able to print and submit (with  no address) so I was able to request this in the covering letter; but for how long?

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Replying to Mr_awol:
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By tlang98413
13th Jul 2015 12:06

P11DX backdating

In our experience HMRC automatically backdate the dispensation approvals to the start of the tax year in which the application is submitted so no need to request it.

For once something that does work!

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By johnjenkins
02nd Jul 2015 14:49

If the forms

were sent to us for appraisal in the first place then the designers would already have sorted out the problems.

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