If no benefits and expenses are paid that would be entered on P11D sections A to M, but expenses are paid or reimbursed that would be entered on P11D section N, my understanding is that if no dispensation is in place then a P11D will need to be completed and filed by 6 July along with P11D(B), although no class 1a nic will be due. If however, a dispensation is in place then there would be no requirement to file forms P11D & P11D(B) as the benefit is fully matched by a tax deductible expense.
Am I correct in assuming that no penalties can arise from not filing a P11D and P11D(B) if only reimbursed expenses are paid that create no class 1a nic liability, even though the forms technically should still have been filed as no dispensation was in place? Can the £100 per month or part month late filing penalty still be imposed? Also can HMRC penalise the personal tax return for being inaccurate although no tax revenue has been lost?
Any answers would be greatly appreciated.