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SA penalties for directors not registered for self assessment

SA penalties for directors not registered for...

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We've had a glut of penalties issued to directors who aren't registered for self assessment recently.  We've taken on board the general advice on here that just being a director doesn't mean you must prepare a tax return.  I have no reason to doubt this general opinion.

Now, where we have directors who basically just have a salary (i.e.: no dividends, no rental income, nothing that means they should register for SA) we are getting penalty notices for late filing.

I assume we're not alone here, so what are others doing about this?

Thanks in advance

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By K81
19th Mar 2015 13:36

must be registered...

...or would not receive late filing penalty.

The directors have been registered under self-assessment either by HMRC themselves or by the individuals concerned & notice to file must have been issued or late penalty notices would not have been issued.

 

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By Vaughan Blake1
19th Mar 2015 13:36

Confused!

Are the penalties for late registration or late filing?

If they are not registered for SA they won't have had a SATR and can't therefore be late filers!

Late registration penalties are rare and tax geared so should not be a problem.

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By Vaughan Blake1
19th Mar 2015 13:47

Another point - maybe solution

The penalty notices will show the 10 digit UTR.  Get a 64-8 in pdq and you can see when/if the tax return (or notice to complete) was issued.

In the meantime send in appeals on the grounds that the people concerned did not know they had been asked to complete a SATR.

As an aside, what happened last year?  Or are they all newby directors?

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RLI
By lionofludesch
19th Mar 2015 14:04

Return

Many of my clients take less notice of the Notice to Complete a Return than they did of the booklet in the small grey binbag.

They just can't be bothered to read the letter.  They'll cheerfully tell you they didn't get a return. Which is true.  In a way.

The only way to make sure is to check on the SA website.

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By ChrisScullard
19th Mar 2015 15:38

These are people who wouldn't register off their off bat, and we certainly haven't done it.

I thought I saw a thread about this a few weeks ago but can't find it now.  Oh well, I guess we get a 64-8 in place and take it from there

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By Martin B
19th Mar 2015 15:52

Call HMRC

To speed up the process, request your clients to call HMRC directly for clarification.

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By Paul D Utherone
19th Mar 2015 15:53

It will be interesting to receive an update

as to when they were registered (according t HMRC) and when the requirement to file a return was issued, once you have the clients on your Agent list with HMRC Online.

Are HMRC, perhaps, now automatically setting up directors for SA from CH feeds in they same way they pick up and set up the company?

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Replying to JimLittle:
By ChrisScullard
19th Mar 2015 16:46

new companies

Paul D Utherone wrote:

 

Are HMRC, perhaps, now automatically setting up directors for SA from CH feeds in they same way they pick up and set up the company?

I think this is the case as the issues I've had are with new company's and/or directors.  I've not heard anything from some of our director clients who aren't registered for SA who've been directors for some time.

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My photo
By Matrix
19th Mar 2015 17:09

PAYE scheme

I note that when you set up PAYE schemes for Ltd companies it asks who are the Directors so maybe this is the trigger?

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By ChrisScullard
20th Mar 2015 10:39

Update on this situation.  It

Update on this situation.  It appears that HMRC are automatically setting up SA records for new directors, either from CH feeds, payroll info or something else.

I can see from the online record of one client (we did the 64-8 a couple of weeks ago when this came up) that apparently HMRC sent a notice to complete a return.  This is news to me and news to the client.

I have three cases like this (2 directors of same company formed in May 13, the other made a director of a company formed in April 13 appointed in Dec 13).

I find it strange that none of them has a request to prepare a tax return.

All three had low salaries and no dividends and no other reason to prepare a return other than their directorships.

Given that TMA1970 makes no reference to directors what's the way forward here?  Do we write to HMRC, quote TMA1970 and ask them why they were registered in the first place?  The issue is that per HMRC's records a request to prepare a tax return was issued so regardless of TMA1970 a return should have been prepared.

The real problem is that both companies have ceased trading and I have very little to do with either company any more so want this to just go away without doing very much.

Is the simplest answer to just do the returns and persuade the clients that they should have had these letters (and reminders) and if they ignored them that's their problem?

I can't see HMRC backing down over this easily which makes it more trouble than it's worth.

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Replying to steve marsland:
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By stevet
20th Mar 2015 16:21

Form SA251 issued

ChrisScullard wrote:

Update on this situation.  It appears that HMRC are automatically setting up SA records for new directors, either from CH feeds, payroll info or something else.

I can see from the online record of one client (we did the 64-8 a couple of weeks ago when this came up) that apparently HMRC sent a notice to complete a return.  This is news to me and news to the client.

We had a case last year when a new company was formed and a directors 2014 return was issued without our or the clients knowledge. When submitted showing only basic salary information and no dividends or any other income a form SA251 was issued saying no longer need to complete tax return. 

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By nogammonsinanundoubledgame
20th Mar 2015 10:49

Have you evidence to support this?

Not doubting you particularly, but it seems a bit strange that you can be confident that HMRC are setting them up but are unable to confirm from what source.

Anyway, s.8 does not fetter HMRC's authority to issue a notice to directors.  It doesn't have to name directors as particularly deserving of a notice.  There was another very long thread about this a month or so ago.  One correspondent is I think attempting to get a notice cancelled under s.8B, and I shall be interested to see how he gets on.

With kind regards

Clint Westwood

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Replying to SXGuy:
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By Roland195
20th Mar 2015 10:57

I agree

nogammonsinanundoubledgame wrote:

Not doubting you particularly, but it seems a bit strange that you can be confident that HMRC are setting them up but are unable to confirm from what source.

I am also having a hard time believing that HMRC have suddenly taken this upon themselves. Not that they wouldn't, more that they couldn't - they are not exactly known for their joined up thinking.

They do not have the information from Companies House filings for a start - no NI number is required. The payroll seems a bit more plausible however and would be interested in hearing what you find out.

   

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By Paul D Utherone
20th Mar 2015 11:20

If HMRC required a return

there's not a lot you can do but complete and submit and as soon as possible.

You should check the addresses HMRC have for the client and to which they would (should) have sent the notice to file. Make sure the address is correct. If it is not then you may have some scope to say that the notice to file was never received as a reasonable excuse - though HMRC will say 'nothing was returned to us as not known at this address so we presume the notice was validly made'.

At a push you could make an FOI request for the client record and proof that the notice was actually issued, BUT that is something for any appeal against the penalties rather than now I would suggest. The most important thing is to get any outstanding return submitted as soon as possible so that to back up the 'reasonable excuse' claim the situation is corrected as soon after the omission came to light.

As a notice to file has been made, and as they are directors you are unlikely to be able to get HMRC to withdraw the notice, so you are stuck with filing the return as soon as possible and making a reasonable excuse appeal against the penalty on the grounds that the notice to file was never reeived (but see above re HMRC's likely response to that).

We all know what the legislation says, but see my comments elsewhere re Fisher v R&C FTT TC03930

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By Paul D Utherone
20th Mar 2015 11:11

Is it not likely to be coming from

the CT41G information.

HMRC issue a CT41G because CH notify that the company has been set up. The CT41G is submitted and has director details including NI No.

HMRC enter the director details from the completed CT41G and decide that SATR's are required

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By DMGbus
20th Mar 2015 11:31

Directors NOT on CT41G

I set up a company for CT via the online equivalent ["Register for HMRC taxes - Corporation Tax"] of CT41G last year.  At no point were any directors details requested, I have a copy of the online submission, just word searched the .pdf copy "director" and no such word appears.  There was a question "contact details" which had a director's name entered.  No NINO either on the form.

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By DMGbus
20th Mar 2015 11:30

Penalty challenge

To successfully challenge a penalty demand it is necessary to show that no notice to complete an SA return was issued by HMRC to the correct address.   Ask HMRC to prove that the notices were actually issued and to what addresses.

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Replying to NH:
By ChrisScullard
20th Mar 2015 12:18

Tried this

Thanks for all the input.  I am aware of the long thread from a month or so back, damned if I can find it though.

When I spoke to HMRC asking for copies of the letters sent request a tax return I got pretty short shrift on that. 'I'm not sure we can do that.  My screen says they were sent so they should have been sent in the post.  Maybe it got lost in the post'.

As usual HMRC's screens are gospel.  Reality seems rather irrelevant.

Personally I think this is one to give up the fight on.  No amount of challenging will change the fact that HMRC think they issued a request for a return, so they need doing.  Clients won't be happy about not getting the penalty reversed but I'll offer to do the returns FOC instead so the total cost to them is pretty much the same.

Ultimately, these were people on the 'don't renew next year' list anyway so not much lost.

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By Paul D Utherone
20th Mar 2015 13:15

That's a call centre drone, and 'Should' is not 'Were'!

... 'Maybe it got lost in the post' gives you a potential reasonable excuse.

So perhaps the client needs to make a DPA request to HMRC - or you on their behalf with suitable authority - to prove that notices were issued and to the correct address. It seems from previous threads that you ought to be able to make a request to HMRC to see your file, thou their FOI & DPA helpsheets and pages suggest this may not be quite so easy.

How much are the penalties?

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By JamesAnd
20th Mar 2015 13:53

Just because a tax return notice has been sent it does not necessarily mean a return has to be completed - you could appeal under section 8b TMA.

The issue, as has been mentioned in this string and many others, is do HMRC have legal grounds for demanding a tax return for directors in any circumstances.

Some think they do and some have doubts and obviously I am (currently) in the second camp.

What you do next is how much time you want to spend on this arguing with HMRC.

As Nogammon has mentioned, someone else on this site (cbp99 I think), is currently lodging appeals on behalf of a client(s) of his. Not sure how he has got on.

If I ever find myself in this position with a director client, who only has a basic salary and not in higher rate and thus no liability, for the sake of a couple of letters I would definitely be willing to give it a go (which I wouldn't charge to the client as this would be a "test case"). There is obviously no guarantee, and perhaps very little chance of success, but still - you never know!

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By Paul D Utherone
20th Mar 2015 14:59

The trouble is 8B only gives the right to request withdrawal

of a notice to file, but does not tell HMRC when they should/ must do so. That is still effectively at their discretion. So you can ask til you're blue in the face, but they can reply that they do not agree that a return is not required, and that's it.

The explanatory notes to FA13 Sch 51 say:

35. Under the Self - Assessment (SA) regime anyone sent a notice to file a SA tax return by HMRC is required to complete and file a SA return with HMRC.

36. This Schedule will introduce a new power to enable HMRC to withdraw a notice to file a SA tax return (individual, partnership and trustee) when they agree a SA tax return is not required and cancel any late filing penalties  - my emphasis

It's not a right of appeal to a tribunal, but a right to ask HMRC to withdraw, and them to agree if they see fit ... and they won't (or are highly unlikely to agree)

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By nogammonsinanundoubledgame
20th Mar 2015 15:02

@ChrisScullard

I hope you took a careful note of the time of the conversation, as it may have been recorded at their end (assuming that you do not have the wherewithal at your end).  If they are on record as acknowledging that it may have got lost in the post, then it may be harder for them to backtrack from that position.

With kind regards

Clint Westwood

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Replying to I'msorryIhaven'taclue:
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By vinylnobbynobbs
25th Mar 2015 16:41

@ChrisScullard & Nogammon

nogammonsinanundoubledgame wrote:

I hope you took a careful note of the time of the conversation, as it may have been recorded at their end (assuming that you do not have the wherewithal at your end).  If they are on record as acknowledging that it may have got lost in the post, then it may be harder for them to backtrack from that position.

With kind regards

Clint Westwood

 

I can confirm that if you can cite the time you called HMRC and quote to them the telephone number you called from HMRC can recall the recording of the call.

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By JamesAnd
20th Mar 2015 15:14

Agreed Paul...

But...

I would the ask why on what basis in law they are saying no to withdrawing the notice and also refer them to EM4551 and ask why should a director be treated any differently just because HMRC say so - unless the law allows them.

Don't see why this isn't worth a try?

 

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By nogammonsinanundoubledgame
20th Mar 2015 16:58

@stevet


Can you just double check that you DID tick the box on the employment page saying that he was a director of a close company?  We have had quite a few knocked out of the system because someone forgot to tick that box.

With kind regards

Clint Westwood

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By ChrisScullard
20th Mar 2015 17:41

Thanks again for all the input.  While I'm sorely tempted to argue the toss with HMRC over whether a return is due or not, I'm not going to get paid for any of this and it has the potential to eat up a lot of time (and wind me up in the process).

Ultimately the tax returns will take 10 minutes each.  I won't charge the clients and persuade them to accept the penalty (£100 each).  All three cases are going to be ex-clients shortly (as soon as their failed companies are struck off) so not much of problem if they don't like it!

It doesn't feel good taking this attitude but I simply can't afford to do a lot of work and arguing when there is no prospect of getting paid for it.

I will be completing tax returns for all directors going forward though.

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By ianthetaxman
23rd Mar 2015 12:58

An old problem...

I've seen this issue on a number of occasions and had a couple quite recently where HMRC require a return for a director when there is no tax due.  if you quote TMA 1970 at them, they usually reply along the lines that others have highlighted - 'oh, well it's been issued now so they'll need to send a return in' or something like this.

 

I don't believe TMA 1970 gives HMRC the ability to single out directors as requiring returns, and I think their guidance on who must complete a return is incorrect.  The problem, as others have concluded, is that the time and effort required to argue the case has so far, not been worthwhile.  While another tax return is another fee, the client is more likely to simply pay the bill for the return rather than wanting their advisor to rack up huge costs arguing a technical point.

 

I too would be keen to hear how the appeal works out, but if George gets his way, arguing about who needs to file a tax return or not will be like two fleas arguing who owns the dog they live on - pointless!  

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Replying to Bolivar:
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By nogammonsinanundoubledgame
23rd Mar 2015 14:45

Authority not required.

ianthetaxman wrote:
I don't believe TMA 1970 gives HMRC the ability to single out directors as requiring returns
With respect, what has that got to do with the price of fish?  Neither does TMA 1970 give HMRC the ability to single out left handed colour blind individuals to require the submission of a return.  But good luck with any appeal on behalf of a left handed colour blind client stuck with a penalty notice.  At least, an appeal on those grounds.

With kind regards

Clint Westwood

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By Peter Kilvington
23rd Mar 2015 12:58

This may help explain a phone call from Friday

I have not looked into this yet but I am really glad this thread is here.

I had a phone call on Friday from a director of a new limited company who has had a penalty for not submitting a tax return.  He swears blind that he did not get a notice to file which I took with a large pinch of salt.  The company and the director will be a new client at some point this week.

The interesting point however is that the the penalty was sent to the trading address, which is also the Registered Office and not the residential address.  The company has not set up a payroll scheme so HMRC could not have picked his details up from there.  I am not even sure if the company has notified HMRC of it activities.  

Making a big leap here and assuming that the soon to be client has not omitted information HMRC can only have picked up the information from Companies House. 

I was sceptical on Friday I am less so on Monday.

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Replying to JimLittle:
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By Roland195
23rd Mar 2015 13:53

Can this be possible?

Peter Kilvington wrote:

Making a big leap here and assuming that the soon to be client has not omitted information HMRC can only have picked up the information from Companies House. 

But there is not enough information filed with Companies House to enable them to do this, specifically no NI number. Even if they were confident enough they had identified the correct individual from the address & DOB, without the NI number they could not link this to the existing records or even check if they were already in SA.

That said, if no payroll has been set up, no CT41G filed by paper for some reason, if possible now then where else can it have came from?

  

 

 

 

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By pauljohnston
23rd Mar 2015 13:42

If it helps

client rang up on receiving a penalty notice.  She had no untaxed income .  THe Short Answer was that HMRC cancelled the SA REgistration and the £100 penalty.

 

THe way forward should be to get each director to ring HMRC and see what an informal approach may do

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By ChrisScullard
23rd Mar 2015 15:22

@ pauljohnston - was this client a director of a limited company?

When I rang querying this all I got was 'our guidance says that all directors must complete a return' and no amount of quoting TMA1970 was going to change their minds.

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By Paul D Utherone
23rd Mar 2015 17:10

Sounds like she probably was Chris

but the client rang the general helpline and the 'are you a director of a company' question that should presumably be on the the Helpline drones 'idiot cards' was not asked, so the 'not in SA' criteria were apparently met and she got taken out with the penalty cancelled.

On another day, with a different drone ... who knows.

I recall ringing to ask for a client who was not a director and had absolutely no need to be in SA to be marked to not receive returns in the future and the Agent line drone rang through a great long checklist including "are they ..." pick any one of the non legislated HMRC required items (director, investment income >£10k etc) plus things like "are they a member of Lloyds?" - with apologies for the clearly irrelevant questions being asked throughout - and when we got to the end they agreed that no further returns were required.

Rang a couple of weeks later with a similar request and I was told they could not flag someone not to get a return until they had been selected to receive a 2015 return, and I eventually gave up on that Joseph Heller loop and will wait until mid April to try again.

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By eastangliantaxadvisor
23rd Mar 2015 18:47

I wrote about this issue in Taxation http://www.taxation.co.uk/taxation/Articles/2015/03/03/332759/anything-d...
Basically once they are in, there's little some inspectors will do to remove them from self Assessment

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By ianthetaxman
24th Mar 2015 14:04

Point taken Clint, but I think the message is clear - now, what about that section on those right handed colour blind.......

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By timiambeing
24th Mar 2015 20:00

Us too!

...back to 2013 I think, I have spoken to a colleague and he has had dozens! Bloody brown envelopes everywhere over the last few weeks for any number of different penalties, mis-declared pension payments, you name it - who woke HMRC up!!

We have sent an email to all director clients instructing them we do NOT file SA tax returns for them because they don't need to file - but if they get a notice to file then we MUST be told because they haven't a leg to stand on. We have appealed in one case, but not sure what the outcome will be. I even had a long conversation with an HMRC representative who called me back as the lady I spoke to was not experienced enough to comment - he said I was right there is no legal statute in place, but if a notice has been issued then a tax return must be filed regardless. He also said it is most likely the director was registered automatically by HMRC.

Anyway this sort of carry on from HMRC makes us look like we are not doing our job, so from now on all directors will be registered and tax returns filed, it only takes five minutes and the hassle otherwise just isn't worth it! :)

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By lme
25th Mar 2015 06:56

Previous post and my take

Like you, I saw threads etc previously on directors not needing to do tax returns. I had been advising ours to register in line with what HMRC says on its website. The posts etc made me concerned that I may be causing needless trouble and fees. I looked up the legislation, which says anyone must do a tax return if HMRC asks for one. I spoke to HMRC. So far as they are concerned, directors need to do tax returns.  My choice seemed to be:

- continue advising them to register or

- advise them not to and risk HMRC "catching up" and trouble and costs later.

 

I went for the first. It's clear on HMRC's website that they want directors to do tax returns. It seemed, to me anyway, that it might be semantics on whether saying on their website amounted to asking for a tax return. If it clearly says on the website that they need to do one, I am not sure clients have much to gain by waiting to be asked individually. In fact it could store up trouble (and possibly has).

I hope this helps. Happy to be further enlightened if I have missed something.

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By ChrisScullard
25th Mar 2015 13:13

I agree that going forward I'll make sure that we do a return for all directors.  Even though there appears not to be legal requirement if HMRC are going to register all new directors themselves (and then not inform anyone) I think it's sensible to make sure all are registered and SA returns done.

It appears it's less hassle to do them than have these situations arise. We also get to charge a few quid more as well so it's not all bad.......

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By Roland195
25th Mar 2015 13:35

Confusing two separate issues

This thread appears to be confusing two separate issues - the whole are all company directors required to do tax returns of which we can all at least concede that they are not unless one has been issued   and the fact that it seems HMRC may have taken it upon themselves to register company directors somehow, perhaps without informing them.

The first issue probably takes up 75% of the server space at Sift and I have no interest in debating that further but the second issue is particularly interesting, at least to me.

Firstly, where are they getting the information regarding directors from? As I have mentioned before, the information they would require on an SA1 is not filed with Companies House. I thought payroll to be the most likely source but some have stated that no schemes were set up.

HMRC are not known for such independent action and the various departments do not seem to be great at communicating at the best of times.

Secondly, are notifications to deliver returns actually being sent and at what point?

 

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Replying to bernard michael:
By ChrisScullard
25th Mar 2015 18:56

.

Roland195 wrote:

This thread appears to be confusing two separate issues - the whole are all company directors required to do tax returns of which we can all at least concede that they are not unless one has been issued   and the fact that it seems HMRC may have taken it upon themselves to register company directors somehow, perhaps without informing them.

The first issue probably takes up 75% of the server space at Sift and I have no interest in debating that further but the second issue is particularly interesting, at least to me.

Firstly, where are they getting the information regarding directors from? As I have mentioned before, the information they would require on an SA1 is not filed with Companies House. I thought payroll to be the most likely source but some have stated that no schemes were set up.

HMRC are not known for such independent action and the various departments do not seem to be great at communicating at the best of times.

Secondly, are notifications to deliver returns actually being sent and at what point?

 

 

Roland - I totally agree with everything in the first half of your post.  It's irrelevant whether directors NEED to do a return, HMRC believes they issued a request so that overrules everything.

The individuals in question in my examples are not the type to do anything off their own bat, like register for SA.  I can easily believe that, individually, they didn't open (or did and ignored) the request to prepare a tax return, but it's a push to believe that they ALL did that.  Any one of them, believable.  All of them, that's pushing it.

Funnily enough, we have other directors who we've never prepared returns for who's companies were formed in previous years.  Never heard anything about these people from HMRC.  More to the point they've heard nothing FROM HMRC.

I can only assume that data is taken from Companies House and HMRC are registering directors themselves.  I also can only assume they are then not telling them, hence the confusion.

The fact that others havet the same issues suggest this is a generic thing.

Solution?  Advise ALL directors they should do a tax return regardless to avoid this exact situation.  Either leave the ball in their court or do it ourselves and charge a little extra fee for it!!

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By pauljohnston
25th Mar 2015 15:49

Roland

Following a recent incoporation the directr received a letter from HMRC reminding/informing him  that he should make sure that taxes are paid on time.  It is not a great leap from this point for HMRC to do a post code check and find the Nat insurance number and record and issue a tax return.

In this case the director had only recently arrived in the UK and therfre did not have a NI record or number

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By cbp99
25th Mar 2015 18:44

.

As was mentioned above, we have submitted a complaint to HMRC regarding their insistence on requiring a director client, with Paye income of £7,692 in 2013-14, and no other income, to complete a tax return. In particular, we cited the Taxpayers Charter which states that HMRC will “do all we can to keep the cost of dealing with us as low as possible.”

We have not yet received a reply, and I have just sent off a reminder to HMRC.

With regard to appeals, in September we were approached by a high income (c£120k) Paye taxpayer who had just received penalty notices for non-filing of returns for 10-11 and 11-12. He appealed on the grouinds that he had not received notices to file, and HMRC accepted this and cancelled the penalties (and “re-issued” the returns, which have now been filed). He had not moved house, and I was extremely surprised at HMRC’s response.

So it would appear that appealing on the grounds that the returns were not received may be successful. 

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By Paul D Utherone
26th Mar 2015 07:36

Though it may not achieve anything

perhaps the issue of directors being automatically put into SA by HMRC, without an agent or the taxpayer doing anything, is something that coulud be raised at Working Together meetings?

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By lme
26th Mar 2015 13:33

Thanks Chris & Paul, cbp (and others)

 

Your comments do give me some comfort that we are doing our best for our directs on this, and treating them fairly, after recent alarm that we might not have been, when we read previous posts insisting that they should not need to (or perhaps did not need to) complete returns. I hate when things catch up with clients after they thought the were in the clear, and so do they. ours in general don't like taking to many risks.

 

 

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By MSD1968
26th Mar 2015 14:54

Hungry dogs?

Two clients, different surnames, each a director of a different limited company but living at the same address. Both received penalties for failing to file. Both are adamant that no notice was received. I did have a conversation with one in December along the lines of - are you sure, are you really really sure? Without a UTR, how can an agent seek authorisation to check? There are dogs in the house but surely they can have eaten both notices without trace? I am suspicious that HMRC did not, in fact, mail these notices whatever they may say. I have appealed both.

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