More confusion over P11D forms

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Accountants fear that their clients will soon receive erroneous penalties for late submission of P11D forms. In most cases, those forms were submitted on time.  

Needless reminders

HMRC’s computers have been spewing out hundreds of reminders for 2016/17 P11D forms. In many cases, a P11D was not technically required, as from 6 April 2016 most reimbursed employee expenses are wholly exempt from tax and should not be reported on a form P11D.

However, as I explained on 30 June, where a notice to file a P11D for 2016/17 was issued by HMRC, a nil return or an online declaration that no class 1A NIC was due, should be filed with HMRC to avoid automatic penalties from arising.

Pointless penalties

The penalty for an inaccurate or late form P11D can be up to £3,000 per form (see HMRC compliance manual COG914080), so the maximum penalty for each employer could be significant.

The Employer Bulletin issue 66 advised employers and tax agents to use the online structured email to inform HMRC that no P11D return was needed for 2016/17. However, even where this online declaration was made correctly, HMRC has sent out letters asking for submission of the P11D form.

AccountingWEB member kerscliff has received dozens of reminders to submit P11Ds, although he did submit nil P11Ds on time. HMRC advised kerscliff by phone that the paper P11D forms he submitted probably haven’t been processed yet, which begs the question: why are they chasing for submission of forms which are waiting to be processed?


Is this another indication of systems breaking down within HMRC? 

About Rebecca Cave

Consulting tax editor for I also co-author several annual tax books for Bloomsbury Professional and write newsletters for other publishers.


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08th Aug 2017 12:44

My favourite last week was a P11D reminder received for 2016-17 on a client where we had already submitted the none required declaration online.

The reminder was issued in the former name of the company, which changed in September 2015 but retained the same PAYE scheme reference.

So potentially we can expect a penalty notice coming through for a company which in name (yes I know, it's still the same legal entity etc) hasn't existed for the best part of two years and had no requirement to submit a P11D in the first place.

Quite how HMRC expect anyone to have confidence in their ability to deliver projects like MTD when they can't get simple stuff like company names right, who knows?

Thanks (2)
09th Aug 2017 10:26

I have had a good half dozen reminders for late
P11ds to be submitted where there were benefits and P11ds were submitted online in plenty of time. Its infuriating.

Thanks (1)
09th Aug 2017 11:59

If HMRC want to be notified when a P11D is not due, why did they remove the tick-box on the year-end EPS submission?

Thanks (2)
09th Aug 2017 12:36

We phoned HMRC mid June as we weren't sure what reporting was needed when no Piid is required. ( letter says reporting through RTI but we couldn't see anything to tick anywhere within RTI ) and of course teh P11d online forms don't allow you to submit a nil return. We were told there was absolutely nothing to do if no P11d is mention of needing to do a nil return...
Presumably there can;t be a penalty for late submission if none was due?

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17th Aug 2017 08:01

We couldn't see anything to tick anyplace inside RTI and obviously teh P11d online structures don't enable you to present a nil return. We were advised there was literally nothing to do if University Assignments | Prime Assignment no P11d is specify of expecting to do a nil return... Probably there can;t be a punishment for late accommodation if none was expected

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22nd Aug 2018 13:06

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