New form CT600

New form CT600

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Apologies if this has been discussed already, but how are members having their clients approve new forms CT600, given that there is no facility (or requirement, it would seem) to sign the declaration? (We already accept email and telephone approval where clients prefer that - but it's convenient when sending the form to them to ask for their signed approval).

Replies (51)

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By Duggimon
21st Jan 2016 14:10

You could have them sign it anyway?

I'm not sure what we'll do, I don't think I've seen anyone using the new form yet but I expect it will either be a digital signature through our accounts software which we already use for some clients or we'll have them sign the thing anyway, box or no box!

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By Andp
21st Jan 2016 14:23

IMO each tax return  should

IMO each tax return  should contain a box for a signature , whether is it actually signed is another matter.

Some clients are going to question me as to why there is no signature box . what a carry on .

Who designs these returns?

and there is another 3 pages to check compared to CT600(2008) version 2 - 8 pages long and 

there is not a "short" version either 

 

 

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Replying to SXGuy:
Tony s
By Tony S
21st Jan 2016 14:50

The new form is a joke

Andp wrote:

IMO each tax return  should contain a box for a signature , whether is it actually signed is another matter.

Some clients are going to question me as to why there is no signature box . what a carry on .

Who designs these returns?

and there is another 3 pages to check compared to CT600(2008) version 2 - 8 pages long and 

there is not a "short" version either 

 

 

 

It's a joke. No signature box, no short version!.. I realize the new return can only be submitted on line but all my Ltd company clients sign a hard copy of their returns as part of the review meeting...

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By ireallyshouldknowthisbut
21st Jan 2016 14:59

.

I agree, its really not been designed with much if any thought, has it?

 

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By mabzden
21st Jan 2016 15:46

Clients don't need to sign tax returns

To the best of my knowledge clients no longer need to sign any tax returns - they just need to confirm in some way that they're true to the best of their knowledge and belief.

So I don't think the lack of a signature box is an accident, as HMRC is trying to push accountants and clients away from the mindset of signing paper copies. HMRC doesn't don't want to process paper returns, and long term they'll probably do away with fixed tax return forms altogether.

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By Andp
21st Jan 2016 16:03

Sometimes you just cannot beat an idiot proof watertight signature.

 

Also ,I have several clients over the age of 70 years. 

They have always physically "signed" off in person , some with their own fountain pen , and point blank refuse to use a computer.

fair enough I say..

I'm all for improvement,advances and generally making things easier /better , 

but removing the choice to sign something !!!???

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Replying to ketteringUK:
By Mike Roberts
22nd Jan 2016 13:10

We know HMRC arnt the cleverest bunch of people so its no suprise to me that they would miss out something as simple as a signature box, if you have clients who do not have access to internet and have always had paper versions, just get them to sign anywhere on the tax return, every page if need be, then you have your proof :)

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By Andp
21st Jan 2016 16:04

the law is an [***] sometimes

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By andrew55
21st Jan 2016 16:09

Who cares?

I'm not sure I do.

If I did I'd add a page of my own design with a disclaimer an signature space.

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By ireallyshouldknowthisbut
21st Jan 2016 16:11

.

Signing the bottom of a document is very simple and well understood procedure.

Remove this, and we have to invent a new procedure, which is rather maddening in my book.

Unless of course you just bash in returns without no authorisation and to hell with your insurance, ethics, or for that matter your clients who might be thinking about it, and not actually want you to file....

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By Ruddles
21st Jan 2016 16:12

I think the point is that the return still includes a declaration that the return is complete and correct etc. Those words are pre-printed on the form, so how can the taxpayer actually make the declaration if he doesn't sign anything? Is the act of submitting the form to be seen as making the declaration?

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By Duggimon
21st Jan 2016 16:34

So what happens in the situation when we send in a tax return on behalf of a client, it's processed, the demand issued and the client says "I never agreed to that return"

Previously we had the signed document saying they did, what would we do now that everything is computer generated and submitted without the client touching it?

I mean, it's not a situation that's ever happened to us but I'd always seen the signed page we kept as a sort of protection against that hypothetical situation.

The issue of what the revenue wants or doesn't want is irrelevant IMO, I've never in my (admittedly short-ish) time as an accountant seen a signed page go to them, it's always been more of a guarantee to us that if anyone did come asking we could prove the client agreed to what we sent on their behalf.

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RLI
By lionofludesch
21st Jan 2016 16:41

To be fair, it's not rocket science to produce a declaration along the lines of the "client declaration" for self assessment forms.  Or to simply get the director to sign the return. But why HMRC should actively encourage the absence of a signature authorising the return is beyond me.

Once again, it gives the impression that the important thing is submitting the returns.  Whether they're accurate is less important. 

Compare RTI - submit first and hope there are no changes before the wages are paid.

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By mabzden
21st Jan 2016 16:47

There are other ways

It's important to get some sort of written confirmation from the client to say the return is true to the best of their knowledge and belief. That way it they do ever claim not to have approved the return you can point to the email.

The move away from physical signatures helps clients and accountants as well as HMRC. You can get an email confirmation from a client far quicker and far more easily than getting their physical signature. So why would we complain?

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Replying to Mr_awol:
RLI
By lionofludesch
21st Jan 2016 17:43

Speed

mabzden wrote:

It's important to get some sort of written confirmation from the client to say the return is true to the best of their knowledge and belief. That way it they do ever claim not to have approved the return you can point to the email.

The move away from physical signatures helps clients and accountants as well as HMRC. You can get an email confirmation from a client far quicker and far more easily than getting their physical signature. So why would we complain?

Speed is not always an issue.

Having the client understand what he's signing/approving definitely is.

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Replying to Jason Croke:
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By Cloudcounter
21st Jan 2016 21:28

Client understanding what they are signing

lionofludesch wrote:

Speed is not always an issue.

Having the client understand what he's signing/approving definitely is.

Speed is always possible, even if not an issue

Having the client understand what they are signing is not always possible

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Replying to Mr_awol:
Tony s
By Tony S
22nd Jan 2016 08:43

why remove the option to sign?

mabzden wrote:

It's important to get some sort of written confirmation from the client to say the return is true to the best of their knowledge and belief. That way it they do ever claim not to have approved the return you can point to the email.

The move away from physical signatures helps clients and accountants as well as HMRC. You can get an email confirmation from a client far quicker and far more easily than getting their physical signature. So why would we complain?

 

Yes you can get email confirmation, but what do I do when I meet a client face to face? as I do with all my ltd. co. clients?? There is no box to sign? I suppose I could ask the client to email me confirmation when they get home....??

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Replying to Southwestbeancounter:
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By mabzden
22nd Jan 2016 15:15

Well...

Tony S wrote:

Yes you can get email confirmation, but what do I do when I meet a client face to face? as I do with all my ltd. co. clients?? There is no box to sign? I suppose I could ask the client to email me confirmation when they get home....??

Confirmation by email is one option but not obligatory. So if you meet a client face to face you may want to get some other form of written approval. You may even - if you know and trust the client - accept their verbal approval, and make a note of the meeting to record that approval was received. But, obviously, it's best to get their approval in writing.

There are lots of options Tony...

Are you actually sending the signed form anywhere? Or is it just for your own records?

(PS. It's best to get their approval in writing.)

 

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Replying to ireallyshouldknowthisbut:
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By Andp
22nd Jan 2016 11:52

?

mabzden wrote:

Tony S wrote:

Yes you can get email confirmation, but what do I do when I meet a client face to face? as I do with all my ltd. co. clients?? There is no box to sign? I suppose I could ask the client to email me confirmation when they get home....??

Confirmation by email is one option but not obligatory. So if you meet a client face to face you may want to get some other form of written approval. You may even accept their verbal approval, and make a note of the meeting to record that approval was received.

There are lots of options Tony...

Are you actually sending the signed form anywhere? Or is it just for your own records?

 

lol chuckle lol chuckle ....I hope you are pulling my chain but if you are serious....

so you are standing there with client at the first tier tribunal - commissioners eyes staring right through you - client denying all knowledge of any wrongs, and back stabbing you claiming my agent signed not me , wiping the egg from your face you reply "honest m'lord - it is with regret I did not seek his autograph BUT he did verbally approve and here is my file note to prove it ".

thank you for cheering me up during yet another gloomy January . have a good week end.

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By Ruddles
21st Jan 2016 16:48

I don't consider it to be a major issue

And I should perhaps have made that clear.

We can get the client's approval in other forms - recorded telephone conversation, email, fax whatever, even client's autograph anywhere on the form. Provided that I have something on file that indicates that the client has approved the return (regardless of whether or not he has actually read it) I'm happy. I just happen to believe that HMRC haven't thought through the absurdity of including a declaration on a form and then providing no means of actually making the declaration.

At the end of the day, clients will complain whether or not they've signed anything - they'll just whine that it is the accountant's job to get things right and that their signature on something they haven't read isn't worth anything. And we all know what we'd like to say in return to such clients.

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By arshadali
21st Jan 2016 16:51

Get them to sign next to their name

I always get a signature, much prefer it. I have sent out a few of these new ones and ask them to sign next to their name.

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RLI
By lionofludesch
21st Jan 2016 18:26

Boxes

Is it me or do all those little boxes imply completion with a biro ?

Weird.

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Should Be Working ... not playing with the car
By should_be_working
21st Jan 2016 20:47

There is a Declaration Box ... Sort Of

There is a declaration box at the end, so generally I suspect we will be planting the e-signature box (we use Adobe Echosign) where the 'Name' box is.

Alternatively have them sign the actual computation right under the 'tax payable' figure - that's all they're interested in anyway.

Not convinced the design flaw isn't just a bureaucratic [***]-up though.

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By PALacc
21st Jan 2016 20:38

I have used the form once already - I drew a line next to the name of director and date and got them to sign that.

It might not be a requirement but it's for my piece of mind that there is a signature there that the director has approved it.

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By thomas34
22nd Jan 2016 08:11

Meaning of Life

Whilst some people are hypothesising about how to get a signature on to a form with no relevant box I'll continue my practice of the past 28 years by taking advantage of CTM93170 and signing all CT600s as agent.

 

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By DMGbus
22nd Jan 2016 08:49

Declaration - cover sheet to CT600 example

Company Tax Return for the year/period ended 31 March 2015
This is a copy of the return, or amendment, including any supplementary pages and attachments for you to review and approve prior to submission to HM Revenue & Customs (HMRC).
Where the return includes nomination details for a repayment to be sent to a bank, building society, other nominee or charity, this will be taken by HMRC to be formal approval of the nomination.
The HMRC IRmark assigned to your Company Tax Return is:
NKMZXPJ7KGDIE2AJQZ7FRCCQM2E8B5RY
Please sign and return this declaration.
Declaration
The information I have given in this Company Tax Return, any supplementary pages and attachments is correct and complete to the best of my knowledge and belief and I approve its transmission to HM Revenue & Customs using the Corporation Tax Online Service.
_______________________

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By Andp
22nd Jan 2016 08:57

wow we are obviously split on this signature box issue.

The tax return is a very very important document. I personally take comfort when the client personally signs off.

By signing ,the client subconsciously , despite varying levels of IQ, is fully aware of the importance and seriousness regarding the content of the return.

Furthermore , the signature helps their understanding that responsibility for accuracy of raw data lies at THEIR door.(not ours)

IMO it is our duty to ask the right questions and extract that data and then perform calculations and claim reliefs accordingly.

@thomas34 - you are a very brave person but you obviously have your own rationale for signing ALL CT600's as agent. I shall never share your sentiment. 

Other members and I have our own quality controls, and the oh so old fashioned time consuming formality of client signature is part of that process.

 

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By Tim Vane
22nd Jan 2016 09:02

A lot of commercial software provides a declaration form (similar to the example given by DMGbus) which is a single sheet containing the IRmark.  This can be included at the front of any tax return when printed or exported. We generally prefer this for all types of return since it is a standard page that is the same for any client of any type.

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Tony s
By Tony S
22nd Jan 2016 09:08

I will use a declaration, but I'm not happy...

Thanks DMGbus

I will get clients to sign a declaration. But it would be a lot neater if the client could sign the bottom of a 4 page short form as they used to.

I know a lot of  clients don't read through the whole tax form but some actually do like to know what they are signing, and quite right too!

An 11 page form of mainly empty boxes is a backward step. 

 

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RLI
By lionofludesch
22nd Jan 2016 09:34

Plenty of space

There is, actually, plenty of space to sign next to the signatory's name.

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Tony s
By Tony S
22nd Jan 2016 11:24

A lot of clients are not comfortable with other options. IMO

mabzden

I get a signed copy for my own records and peace of mind. But also I think it's common courtesy (and professional) to give a client the opportunity to look through something that they are putting their name to.

I'm more than happy to accept email confirmation, or other method (except verbal)  if that is what the client is comfortable with! No matter what we think not all clients are comfortable with something other than a signed piece of paper. It is their business , their livelihoods and their money.

 

 

 

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paddle steamer
By DJKL
22nd Jan 2016 11:28

Managing paper

One reason for having signed versions of things is that you then tend to know that it was that particular version that was the final version; when say preparing accounts I may end up printing and proofing up to say four versions. (I cannot proof on screen, I always miss something)

Now if the versions are marked as drafts and destroyed no issue, but if at busy times the organisation goes a bit awry signed returns/accounts etc are a godsend when filing to ensure the correct version is  put in the file.

(Above does not apply if you are a paperless type, I am not)

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By mabzden
22nd Jan 2016 13:00

I'll hold off answering that....

... until the day I'm hauled up in front of the First Tier Tribunal (presumably after an armed raid by Interpol's tax return signature unit) and they're demanding that I explain exactly what approval process I went through before submitting a client's CT600.

Maybe instead of worrying so much about getting a signature on a piece of paper that isn't being sent anywhere, you need some new clients? Your existing clients must be a dodgy bunch who obviously can't wait to pass the blame on to you?

Anyway, as it happens I wouldn't normally rely on a verbal authorisation and would want something in writing.

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Replying to Matrix:
RLI
By lionofludesch
22nd Jan 2016 13:31

Weak

mabzden wrote:

Anyway, as it happens I wouldn't normally rely on a verbal authorisation and would want something in writing.

All your posts on this thread are weakened by this last sentence.

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By thomas34
22nd Jan 2016 13:16

If

the hundreds of CT returns that I've signed as agent don't tally with the accounts as approved by the board of directors then I reckon I deserve to be sued.

 

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By Andp
22nd Jan 2016 13:27

@mabzden thank you for confirming you were being serious. And a second thank you for making me chuckle but I am easily amused.

You are correct I do need some new clients - who doesn't ?

Now ,maybe with some embarrassment and / or desperation you have lowered yourself into making personal allegations that my clients are a "dodgy bunch". 

It is my understanding that they are not. As I fear the wrath of my institute , if I were to service such individuals.

I am very pleased to hear though that you do prefer something in writing afterall.

 

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By mabzden
22nd Jan 2016 13:56

You win(?)

lionofludesch wrote:

mabzden wrote:

Anyway, as it happens I wouldn't normally rely on a verbal authorisation and would want something in writing.

All your posts on this thread are weakened by this last sentence.

It sounds an uncontroversial statement to me?

Anyway, I'll let you score you and andp score your points if it's that important to you. If you want to carry on as you've always done, because that's the way you've always done it, then that's your right and good luck to you.

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Replying to Barbara G:
RLI
By lionofludesch
22nd Jan 2016 14:18

Score points ?

mabzden wrote:

If you want to carry on as you've always done, because that's the way you've always done it, then that's your right and good luck to you.

You mean, like you, I want something in writing ?

Sure - go on, try to put me down as some luddite whilst admitting you like to do the same.   Makes sense ......

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By mabzden
22nd Jan 2016 14:33

We agree

Finally, we agree! Best to get the client's approval in writing. And I'm sure andp agrees too.

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Replying to DJKL:
Stepurhan
By stepurhan
22nd Jan 2016 14:57

Everybody else already agreed

mabzden wrote:
Finally, we agree! Best to get the client's approval in writing. And I'm sure andp agrees too.
As far as I can see, you're the only one that said

mabzden wrote:
You may even accept their verbal approval, and make a note of the meeting to record that approval was received.
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By mabzden
22nd Jan 2016 15:08

True...

...but obviously it's best to get the approval in writing.

I've edited my earlier comment appropriately just to make this very clear!

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RLI
By lionofludesch
22nd Jan 2016 16:56

Obviously .....

Yes ..... obviously.

The paperless office is a timebomb.

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By petestar1969
25th Jan 2016 13:06

Err

Why would they need to sign something that is filed electronically?

I stopped asking clients to sign stuff years ago. I send it by email and say "Please reply to this email indicating your approval of the attached."

I make it clear to them that nothing will be filed without the email and payment of my fees...

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RLI
By lionofludesch
25th Jan 2016 13:01

Grand

If you're happy with that, grand.

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By andrew55
25th Jan 2016 13:07

What is really in a CT600?

How many do you really do which don't just set out information from the accounts the directors have signed? In our case it's the few with R&D and TTR claims and I'd have got those figures agreed separately anyway.

99.9% of our CT600s are actually really basic. SATR's are a different kettle of fish as there are potentially many different errors or omissions and I wouldn't dream of a client NOT approving theirs.

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By mabzden
25th Jan 2016 13:40

The times they are a changin'

I don't think the lack of a signature box on the form is an error or because HMRC isn't very bright. You can't file a CT600 in paper format, and from an admin perspective HMRC doesn't want firms sending in their CT600s in paper format because they're a bit confused.

So the removal of the signature box is, I imagine, a deliberate act to try to prevent this happening.

 

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RLI
By lionofludesch
26th Jan 2016 13:10

Yet ....

Yet HMRC expect we accountants to satisfy ourselves that the details we submit are correct.

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Replying to Mr_awol:
Euan's picture
By Euan MacLennan
26th Jan 2016 14:21

Are you saying ...

lionofludesch wrote:

Yet HMRC expect we accountants to satisfy ourselves that the details we submit are correct.

Are you saying that a client's approval - whether by signature, e-mail or verbal - makes a tax return correct?

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RLI
By lionofludesch
26th Jan 2016 14:49

Unjustified

I think I was - and, of course, that's unjustified and you're right to raise the point.

However, I like to have some assurance and record that the client has approved and acquiesced to the details that I am submitting on his behalf.

I like to do this with a signature.  I consider it useful to go through the figures in a final review at a face-to-face meeting. Others may have other requirements but I will stick with my own thoughts which, I might add, nothing in this thread has influenced me to reconsider.

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By mabzden
27th Jan 2016 10:45

Why do we still have a paper form?
Rather than asking why there's no signature box, to me the more interesting question is "why do we still have a CT600 form?"

The CT600 data has to be filed online, either through the HMRC portal or using third-party software. The client needs to see something (i.e. a tax calculation) representing the data that's being filed on their behalf and showing all the relevant entries and calculations.

But do we need a fixed, 11 page form containing numerous boxes, the vast majority of which are normally empty? And once this "form" has been filled in, it doesn't ever go anywhere.

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