Declaration of compliance issues

TPR not recognising Letter Code

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I am trying to add employers for DOC. I get the letter code from the TPR website using the employers PAYE details. The TPR provide the letter code and then when I try and add the employer, the TPR website says it doesn't recognise details yet less than a couple of minutes ago they just gave me the letter code. Its the same when I try and tell TPR that the client is not an employer. 

Am I doing anything wrong or is anyone else having the same issues?

Friday night and I have to deal with this.....

Replies (15)

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By Matrix
16th Feb 2018 22:12

TPR has marked some Director only payrolls as not having any workers so no declaration is necessary. We check all of them on a case by case basis as it is quite random.

If you are concerned then either email or call TPR to check that no declaration is required.

Although since we have an email from TPR saying no action is required for Director only schemes, if the letter reference does not work I think we have started doing nothing (since you can't actually file a DOC as you have discovered).

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By thomas34
17th Feb 2018 08:31

Agree with Matrix - it's yet another shambles we have to deal with. My problems have been more advising TPR by the staging date that the company has no workers and the letter code not being recognised. It's correct that HMRC have been advising TPR of single director companies and removed codes from their list. How HMRC (and TPR) know that the company's director doesn't have a service contract I don't know. In every case I've phoned TPR (who have always been helpful) and checked the status and they've always e-mailed me with confirmation.

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RLI
By lionofludesch
17th Feb 2018 08:48

Yes - apparently it's something to do with director only payrolls. I have two of these at the moment - one of which isn't a director only payroll, though the employee hasn't topped £833 in any month so far.

I'm going to send a letter and tell them to sort it out. A phone call's not good enough - I want some acknowledgement that either a DOC has been filed or they don't want one.

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Replying to lionofludesch:
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By Matrix
17th Feb 2018 08:57

If it is already marked as no workers then there will be no staging date and it would not be physically possible to file (or fail to file) a DOC.

For the scheme which will have a worker, TPR can change it over the phone and give you the new staging date (don't all employers stage straightaway now anyway).

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Replying to Matrix:
RLI
By lionofludesch
17th Feb 2018 09:05

This is one which, bizarrely, had a staging date after the date when new businesses had to stage immediately.

Anyway, the point is that this company doesn't have any employees earning £833 a month but neither is it a director only company.

Once again, a simple task of filling in a DOC is made more complicated by folk trying to be helpful but not really thinking out the consequences of their bright idea.

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Replying to lionofludesch:
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By Matrix
17th Feb 2018 09:24

Yes I have some of them too. We have spent a lot of time getting letter references, staging dates and completing or not completing DOCs since we would hate clients to get penalties.

For your payroll client I assume you just complete the DOC saying no workers on the staging date. I assume the job holder is entitled so has been offered to join a scheme.

I have a few new payrolls being set up before April, I don't see how they can be marked as Director only if they stage straightaway and no RTI submissions made? Will have to see, the randomness is most unhelpful.

Maybe they could put a box on the PAYE application but start ups often have no employees and this changes.

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Replying to Matrix:
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By lionofludesch
17th Feb 2018 09:35

The old way was more clear cut.

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Replying to Matrix:
Euan's picture
By Euan MacLennan
17th Feb 2018 17:33

Matrix wrote:

For your payroll client I assume you just complete the DOC saying no workers on the staging date. I assume the job holder is entitled so has been offered to join a scheme.

For clarity, if you have no workers at all, you do not submit a DOC, whether on the staging date, the postponement date or for new PAYE schemes, the date when employer duties start - you file a notification that you are not an employer. If you have workers, but none that need to be enrolled, you submit a DOC saying that no workers have been enrolled.

My gripe is that when trying to submit a notification that you are not an employer, the TPR website reports a mismatch between the letter code and PAYE reference if TPR has already marked the PAYE scheme as not being an employer. Although you think you know the reason for the "mismatch", you still have to waste your time and that of TPR's helpline staff to confirm the reason in order to ensure that your client will not be penalised for failing to notify. It appears that TPR's systems are incapable of reporting the true reason that the PAYE scheme has already been marked as not an employer.

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Replying to Euan MacLennan:
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By lionofludesch
17th Feb 2018 17:34

"If it ain't broke, don't fix it."

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Replying to Euan MacLennan:
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By Matrix
17th Feb 2018 18:12

But Lion's client is going to have a worker soon so he may as well complete the DOC. If the scheme is marked as not an employer then it will have to be changed when a scheme is required.

Please see my posts above - if the letter reference does not work it is not possible to file a DOC so I do exactly that - I assume the scheme has been marked as not an employer. I have spent a lot of time on this and have an email from TPR. As already pointed out by others tho, they are not consistent so I check every scheme and file the DOC if required.

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Replying to Matrix:
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By lionofludesch
17th Feb 2018 18:23

Matrix wrote:

But Lion's client is going to have a worker soon so he may as well complete the DOC. If the scheme is marked as not an employer then it will have to be changed when a scheme is required.

Had one for six months before staging date, actually. But the most she has earned so far in any one month is £816.

It's probably a Government plan to lure employers into a £400 fine trap.

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Replying to lionofludesch:
JCACE
By jcace
18th Feb 2018 16:30

Where an employer was given a staging date, but TPR update their records to show "Not an Employer", you will need to phone TPR to advise them of the date on which the employer becomes an actual employer, as this may well change the original duties date. Any employer that TPR believe is Not An Employer, but who subsequently employs someone after 1 October 2017, will have their duties start immediately. TPR will therefore need to be advised any time that a non-employer becomes an employer.

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Replying to jcace:
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By lionofludesch
18th Feb 2018 17:08

How is this better ?

Bearing in mind that TPR couldn't be bothered to let companies know that they'd crossed the company of their list of potential employers.

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Replying to lionofludesch:
JCACE
By jcace
18th Feb 2018 21:04

I agree. It would be much better if TPR's systems could let NAE employers know that they have already been treated as NAE... with an easy option for the employer to use to inform TPR when they become an employer.
However, I do not believe that TPR are out to make money out of fining employers, at least not yet. I had one client who TPR believed was NAE, but before their original staging date took someone on below the AE threshold. When I tried to complete the DoC, I couldn't, because TPR thought the company was NAE. When I phoned TPR, and explained, they were quite relaxed and were quite happy to have the DoC filed asap, even though the duties date had changed due to the trigger of employing someone (so that technically they were now late in completing a DoC). Perhaps now that staging dates are out of the way things will become clearer. Perhaps. But I do agree there's more that TPR could do to make this easier for non-employers who subsequently become employers.

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Replying to jcace:
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By Matrix
18th Feb 2018 22:08

When I called up to advise that a scheme now had employees but had been marked as not having any so no DOC required for the original staging date, a new staging date was issued (originally 1 July 2017, new date was 1 Jan 2018).

I don't think they will be able to mark them as not having employees anymore since schemes will stage as soon as they are set up so this issue will go away.

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