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Making Tax Digital moves up a gear

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17th Jul 2018
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HMRC has issued the MTD for VAT notice alongside a communications plan for advisers to use to educate their clients about MTD. There are also now 18 approved MTD for VAT software providers.

VAT notice

This VAT notice 700/22: Making Tax Digital for VAT, expresses the law relating to MTD for VAT in a readable form and includes guidance from HMRC to fill the gaps where the law is deficient. It will be essential reading for all tax advisers and businesses who have to either advise on MTD, or who need to follow the MTD rules from 1 April 2019 or a later date.

The most important parts of the notice are part three: digital record keeping and part seven: examples of digital links (see below).

Exemptions

VAT-registered businesses with annual VATable turnover under the VAT registration threshold (currently £85,000) don’t have to follow the MTD rules, but if they wish to do so they must tell HMRC in writing. No postal address for this is given in the notice, so I assume that all written queries about MTD should be directed to the VAT written enquiries team.

Businesses that want to claim exemption from the MTD rules on the grounds of religion, insolvency, or because it is not reasonably practical to use digital tools (see section 2.2), will have to contact the general VAT helpline to ask HMRC to approve the exemption or provide “digital assistance”.

HMRC will host a webinar for tax agents focusing on this VAT notice on 24 and 25 July, which may explain what form digital assistance may take and whether a dedicated MTD helpline will be provided.

Not fully working

The VAT notice confirms that the full MTD service won’t be available from HMRC when MTD for VAT goes live in April 2019. Businesses won’t be able to submit voluntary updates or supplementary data to support their VAT return. HMRC says these features will be available at a later date.

Record keeping

Information which is required for the VAT return must be kept in a digital form within functional compatible software (see below). Only the information listed below is required; the business doesn’t have to keep a digital image of each purchase invoice.

Some permanent information about the business must also be recorded digitally such as the name, address, VAT number and any VAT accounting scheme used.

For each VATable supply made by the business it must record:

  • time of supply (tax point)
  • value of the supply (net value excluding VAT)
  • rate of VAT charged

The business doesn’t have to record the amount of VAT charged, as presumably the software will calculate this. It also doesn’t have to record transactions which don’t affect the VAT return, such as supplies within a VAT group.

For each purchase which is relevant to the VAT return the business must digitally record:

  • time of supply (tax point)
  • value of the supply
  • amount of input tax that the business will claim.

A business which is partially exempt or which uses a VAT scheme may not know how much VAT it can reclaim on each individual invoice. In that case, the business has the choice to record:

  • all the VAT paid; or
  • none of the VAT; or
  • estimated amount of the recoverable VAT.

Then once the partial exemption or other scheme calculation is done for the VAT period, an adjustment is made to the digital VAT records.

Digital links

The “functional compatible software” in which the VAT information is recorded can be a number of software programs, products, applications or spreadsheets which are digitally linked together. A digital link is an electronic or digital transfer or exchange of data between software programs, products or applications. This definition has the force of law.

The VAT notice sternly warns that the use of “cut and paste” does not constitute a digital link. However, using digital links between software to transfer data needed for the VAT return won’t be compulsory until VAT periods starting on or after 1 April 2020. This constitutes the “soft landing”, which may be explained in greater detail in the forthcoming HMRC webinar.

There are a number of examples of digital links in section seven of the VAT notice.  

Software

The suppliers which have demonstrated a prototype of their MTD software to HMRC and who have tested their products within the HMRC test environment are listed here, but the links to each supplier’s website do not always take you directly to the software product.

You have to delve around to find the product which may suit your requirements. Some suppliers such as PwC claim to supply spreadsheet-based products, but this “bridging software” is still hard to find. 

Communications

The tax profession has been crying out for HMRC to start marketing MTD to the wider business community, as some clients believe that it is all a ploy to get them to buy expensive and unnecessary software.

HMRC appears to be dodging its responsibilities in this regard, as it expects accountants, professional bodies, and software suppliers to do this marketing for them.

It has produced an MTD for business stakeholder communications pack, which contains messages to pass on to clients, customers and members, plus a link to a video explaining MTD. There is no indication of what HMRC will be doing itself to market MTD to the wider population.

Replies (87)

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Replying to paul s&w:
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By EnglishRose
28th Jul 2018 21:41

They certainly need to learn better English!

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By paul s&w
18th Jul 2018 14:58

internet crashes.... that bodes well for filing under MTD.

Thanks (3)
Tornado
By Tornado
18th Jul 2018 15:19

I am really beginning to enjoy MTD now as it is clearly doomed to failure, but I no longer care. It will be impossible to comply with the myriad of nonsensical rules, so why try?

I would say the MTD is now much more entertaining than Brexit and I look forward to the daily episodes of each. Who needs Coronation Street or Eastenders when we have MTD and Brexit?

Thanks (3)
Replying to Tornado:
Morph
By kevinringer
18th Jul 2018 15:21

And they'll both be kicking off within two weeks of each other. Oh what fun.

Thanks (2)
Replying to kevinringer:
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By johnjenkins
18th Jul 2018 16:00

It's coming home, it's coming home, our future's coming home.

Thanks (1)
Replying to johnjenkins:
Morph
By kevinringer
18th Jul 2018 16:18

Not is isn't. We were beaten by the Balkans. And I'd invested in a waistcoat too.

Thanks (1)
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By anthonystorey
18th Jul 2018 18:03

Who's going to know whether you've transferred data from one thingamabob to another using digital means. I say just do whatever's easiest and don't worry about it. HMRC are going to be too busy clearing up the mess to check whether everyone's complying with the letter of the law.

Thanks (2)
Replying to anthonystorey:
Morph
By kevinringer
19th Jul 2018 05:50

You've stolen my plan

Thanks (0)
Replying to anthonystorey:
By ireallyshouldknowthisbut
19th Jul 2018 17:47

Well quite

They can allow or disallow things until they are blue in the face, but the key is if you pay the right amount of VAT at the right time.

That is the point of HMRC. To collect taxes that are legally due. Process matters little and is soon forgotten about.

Anyone doing really detailed tagging of stat accounts? Or do you bosh through anything that files?

Thanks (3)
Replying to anthonystorey:
Tornado
By Tornado
19th Jul 2018 20:42

The waters are really muddied now and it is difficult to see where we are going, but I think the necessity for a digital link or flow of data through an accounting system is mainly to do with MTD as an ultimate extension of MTD for VAT.

Whilst there is the need for some absurd digital link between a spreadsheet and an API for VAT, eventually HMRC will be trying to force us into using software that reports every transaction in an accounting system, and this is where the spreadsheet will fail as the spreadsheets that businesses of all sizes and Accountants of all sizes use are not designed to do this.

We get over MTD for VAT and then the old problem comes back as the solution we found for MTD for VAT is wholly inadequate for MTD.

The whole situation is appalling and absurd and HMRC are just fighting fires when they should be re-thinking the whole MTD project.

Thanks (1)
Chris M
By mr. mischief
18th Jul 2018 18:56

To the site moderators, can we have a poll please?

Which is the bigger shambles?

A. Brexit
B. MTD

Tough one to call that. A bit like asking if you'd prefer to die by firing squad or hanging.

Thanks (1)
Replying to mr. mischief:
Morph
By kevinringer
19th Jul 2018 05:47

Brexit - no doubt about it because there are some aspects of MTD that could work if introduced voluntarily over a period of time.

Thanks (1)
Replying to kevinringer:
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By johnjenkins
19th Jul 2018 08:54

I hate agreeing with anyone but you got it right Kevin.
Whatever plan we come up with the EU will not like or agree to. So, as I said right from the start, let's stop wasting time and just come out with "no deal".
Ok "what about all our business ties, Northern Ireland, trade etc. etc." I hear the remainers cry. They will all get sorted but on mutual terms (because they have to be).
Back to the plot.
I do actually feel that HMRC (with their watered down approach) realise that it is going to take a lot longer to convince small business to play ball. We now know that the link to each transaction will not be available till 2020.
I'm really not sure of the legality of HMRC being able to have access to every transaction without opening an investigation. I will look into that further - unless anybody already has the answer.

Thanks (3)
Morph
By kevinringer
19th Jul 2018 06:04

Section 6 'Agents will not necessarily have access to all of your source data so, for example, they may not always be able to make corrections to your digital records. In these circumstances your agent will need to advise you of any corrections required to those digital records.'

This means agents don't have to maintain a digital link to the original data. Notice there's no reference to spreadsheets so this applies to any records.

But does this contradict 3.2.1.1 talking about the soft landing 'The one exception to this is where data is transferred, following preparation of the information required for the VAT Return, to another product (for example, a bridging product) that is API-enabled solely for the purpose of submitting the 9 Box VAT Return data to HMRC. The transfer of data to this product must be digital.'

Thanks (1)
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By North East Accountant
19th Jul 2018 08:35

Surely HMRC are going to communicate with businesses affected.

The easy way will be to send them all a letter in Sept/Oct 2018 with a sterner follow up letter, Jan/Feb 2019. Nice and simple.

That's not se*y enough for HMRC so we will probably end up with TV and radio adverts, costing a fortune, instead.

Thanks (0)
Replying to North East Accountant:
Head of woman
By Rebecca Cave
19th Jul 2018 09:59

HMRC has said it WILL NOT write to all affected businesses to tel them about thier MTD obligations. I believe this was confirmed in the CIOT webinar: https://www.tax.org.uk/policy-and-technical/making-tax-digital

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Replying to Rebecca Cave:
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By johnjenkins
19th Jul 2018 10:18

They really are washing their hands of all responsibility aren't they?
This will come back to bite them on the [***].

Thanks (2)
Replying to Rebecca Cave:
Head of woman
By Rebecca Cave
19th Jul 2018 12:02

Correction: I have jsut been told that HMRC WILL be writing to businesses who they believe will be affected by MTD for VAT. HMRC are just deciding on the right time to do this.
I would say that the "right time" is ASAP!!!

Thanks (6)
Replying to Rebecca Cave:
Morph
By kevinringer
19th Jul 2018 12:17

At last HMRC are going to do something. I hope HMRC will liaise with the Institutes about the wording of the letter because HMRC's version will be 'this is wonderful' whereas the institutes are well aware from member feedback of the enormity of the requirement to digitise transactions.

Thanks (2)
Replying to Rebecca Cave:
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By johnjenkins
19th Jul 2018 12:56

That's when the smelly stuff will hit the fan.
HMRC are probably putting it off until they've actually got something to work with, because clients are going to want a demo.

Thanks (1)
Replying to Rebecca Cave:
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By bendybod
31st Jul 2018 12:14

I look forward to the deluge of correspondence from clients asking what on earth it is talking about! So far, every client that I have proactively raised it with has not heard of it.
The alternative, of course, is that the client files it in 'don't understand therefore will ignore' and continue in the blissful assumption that, given that HMRC are introducing it, the HMRC portal will continue to be an adequate way of filing. I have yet to find a client who doesn't ask me 'why' on that one!

Thanks (0)
Chris M
By mr. mischief
19th Jul 2018 11:42

Yes Brexit is probably a bigger shambles as the choice will probably boil down to betting the house with the No Deal escaped lunatics or begging our way back to the EU.

But HMRC are embarked on their stupidest scheme of the past 10 or 15 years. And when you consider how many really daft things, like the pasty tax, have come out of HMRC Towers in that period, this is one hell of a car crash we are heading for.

Thanks (1)
Tornado
By Tornado
19th Jul 2018 12:28

So HMRC have moved their MTD up a gear from 1st to 2nd (although some might say we have moved from 1st to reverse judging by the amount of back-tracking that has been going on).

Still a lot of gears to go until we get anywhere near a decent speed and not that much time to adequately test out if it works properly. Does MTD still need extensive repairs?

One thing is for sure, HMRC are unlikely to get any speeding tickets in the foreseeable future with their MTD, but might get stopped for a breath test due to the wild wandering all over the road with their ever changing route plans. More likely, I think, is that they will be stopped for using a mobile phone whilst moving in their MTD, as they are so obsessed with the damn things.

Perhaps it would be safer for all of us if HMRC was simply instructed to take their MTD to the nearest scrap yard and look for another simpler, more reliable model. MTD may have cost 1200 million pounds but hey, it is far too complicated to be reliable and is not safe, and that is THE most important point.

Thanks (1)
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By jonibarnes
19th Jul 2018 19:30

So I use an ancient desktop version of quickbooks, is no way that I can see of transferring the data out. Am I correct in thinking that during the softlanding period I can prepare the return in quickbooks and then type this in a spreadsheet and transfer across to hmrc via an application such as liquid vat filer?

Thanks (0)
Replying to jonibarnes:
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By adebola
19th Jul 2018 22:36

Yes, it’s that simple. Liquid vat filer also supports both excel and csv files. More information here https://vat.liquidaccounts.com/

Click on the “how it works” link to download our user guide doc.

Also feel free to contact the team at [email protected]

Thanks (4)
By chewmac
25th Jul 2018 22:27

"businesses will need to start keeping digital records and then submit VAT Returns via functional compatible software for return periods starting on or after 1 April 2019."

I have a client who's Annual Accounting year ends 28 Feb 2019. Does anyone know if that means they'll not have to comply with MDTfV until their VAT Annual Accounting period starting 1 March 2020?

Thanks (0)
Replying to chewmac:
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By johnjenkins
26th Jul 2018 08:52

VAT has nothing to do with year ends, although you can get your returns to coincide with your year end. If your already registered and turning over £85k your returns periods are the same. If you are nearing vat threshold then the normal 12 month running total applies.

Thanks (1)
Replying to johnjenkins:
By chewmac
27th Jul 2018 09:19

Thanks John for your reply. I should have been clearer - this particular client uses VAT Annual Accounting with both VAT & Accounts year-end of 28 Feb. Hence first VAT period starting after 1 April 2019 will be 1 March 2020.

We can probably not yet answer this - but I wonder if they will therefore escape their need to comply with MTDfV for another 11 months?

Thanks (0)
Replying to chewmac:
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By johnjenkins
27th Jul 2018 09:39

From 1st April 2019 all registered business with a turnover of over £85K will have to go on MTD as the normal gateway will be shut for them. So whenever your first VAT return is submitted, regardless of what scheme, it will come under MTD, unless exempt.

Thanks (0)
All Paul Accountants in Leeds
By paulinleeds
30th Jul 2018 12:59

I telephoned the VAT helpline, on 0300 200 3701, today to try to find out more about Agent Services Accounts and how the £85,000 limit will be policed. I was initially told that somebody from the MTD team would telephone me in two days' time. I was surprised to receive a call 10 minutes later.

I know some people have commented about reviewing a client’s VAT history since 1973 to see if they had EVER (as this is what the VAT Notice says) exceeded the VAT threshold.

I was told that the £85,000 limit will be decided by the last four VAT returns before the introduction of MTD. If a client has turnover over this amount then access to the VAT filing service on their Government Gateway account will automatically be revoked on 1 April 2018. That appears to be quite clear.

There has been lots of discussion on this thread and others regarding the new Agent Services Account. I think it is now well understood that all agents will need to set up a new Government Gateway account for MTD purposes and that this portal will be used to deal with submissions through compatible software.

I have very easily created my own new Agent Services Account and are linked it to my old Government Gateway account. The latter, for clarity, is where we have and will continue to access our clients non MTD tax details.

I asked the question why my clients had not been pulled through to the new Agent Services Account. I was told that unless I had agreed to take part in the beta pilot that nothing would be shown even though the two accounts are linked. I was told that in a few months' time that some VAT registered clients would appear in the new Agent Services Account.

As mentioned above, I was further told that once we reach 1 April 2019 that have all VAT registered businesses who have a turnover of £85,000 in the previous 12 months (for VAT returns) will automatically be revoked from the normal agent filing service and introduced into the new MTD new Agent Services Account.

Thanks (1)
Replying to paulinleeds:
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By johnjenkins
27th Jul 2018 09:10

I don't see how they can revoke all those with a turnover over £85k from the normal gateway because there are some that can't use MTD for a number of reasons. I'm thinking just the digital side not the internet side.

Thanks (2)
Replying to johnjenkins:
All Paul Accountants in Leeds
By paulinleeds
30th Jul 2018 13:04

I note JohnJenkins comments. However, unless you can apply for and receive an exemption then you must file with VAT MTD for VAT returns after 1 April 2019.

Maybe, if your client has religious issues, poor internet or other disabilities e.g. age then they can turn back on the old Gateway for them.

Without an approved exemption there will be no filing through the 'old' Gateway. If there was I'd continue to use it for all my clients!

Thanks (0)
Replying to paulinleeds:
Tornado
By Tornado
30th Jul 2018 13:33

"Maybe, if your client has religious issues, poor internet or other disabilities e.g. age then they can turn back on the old Gateway for them."

I am not sure that Age is a disability, but it might be worth a try.

Although HMRC seem confident about blocking most people's access to the usual Government Gateway portal from 1st April 2019, in practice, I think this is bound to cause widespread confusion and a dramatic decrease in funds flowing into the Treasury as business of all sizes struggle with the new rules and software that does not work properly & HMRC systems that do not work properly.

It makes no sense for HMRC to deliberately create a situation that not only suppresses much needed tax income, but will also involve countless HMRC staff in trying to sort the mess out and dealing with countless appeals.

This sort of situation is completely unnecessary and I think HMRC will have no choice but to concede to common sense before we get to April and make MTD for VAT optional rather than mandatory

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Replying to Tornado:
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By EnglishRose
31st Jul 2018 10:18

It certainly sounds drastic to me and I unlike a lot of small businesses am aware of the change. I am just waiting to see what product I am forced to buy (my current records are impeccable and kept on paper - unhackable too.....) and then it would be sensible if we could use two systems in parallel for a year or so whilst things bed down surely rather than come 31 May (I think my first filing date after April) there being immediate problems and inability to file or pay.
Also they have not written to us VAT payers yet as far as I can see and it is getting very close. Even if it just involved me having to train myself in something like excel (given I have zero time for that kind of stuff anyway and hate it) that is cutting it very fine and even if they want time to assess and accept applications for exemptions (which I doubt would apply to me anyway) and investigate if the exemption if rightly applied for etc there is still not that much time between now and then.

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