P46(car) and HMRC's own web based software

P46(car) and HMRC's own web based software - is it compliant?

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I am dealing with an employer that has made a car available to an employee, for the first time, on 06 March 2017.  Reg 90, SI2003/2682 requires the employer to file a form P46(car) registering this event, carrying a deadline of 28 days following the end of the tax quarter. This event took place in the quarter ended 05 April 2017, so the filing deadline is 03 May 2017.

We have 64-8 and FBI2 in place for this company as agent for PAYE, and in theory it provides an opportunity to complete and file form P46(car).  Indeed it allows us to complete the form up to ticking the declaration box.

On the page containing the declaration box it says that on the next page we shall be given an opportunity to print the form before submission.  But if I click the "next" link it just takes me back to "employee actions".

Aside from bypassing the "print before submission" option as promised, it remains unclear to me whether the form has even been submitted.  On the "employee actions" page it shows the presence of a P46(car) with status "updated" on "26 Apr 2017".  But it does not absolutely confirm that "updated" means "submitted".

I phoned HMRC online services helpdesk and they said that as we are now past 05 April 2017 we could only file a P46(car) for an event that falls in 2017-18 tax year.  So what happened to the 28 day statutory period of grace for events in last quarter of 2016-17?  They said just file a P11D (which we shall be doing anyway) but the P11D deadline is 06 July and the P46(car) deadline predates that.

As an aside, they also asked me to ensure that the processing year into which I was logged was the 2017-18 tax year.  Well it was not - I was logged into 2016-17, and when I click on the link to change processing year, the drop down list goes up to 2016-17 but does not have a 2017-18 option (not that I can believe that I should be in that year anyway).

Am I doing something wrong?  Apart from snarky responses that I should not be attempting to use HMRC online software, of course.

With kind regards

Clint Westwood

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