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HMRC lights blue touch paper on MTD letters

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6th Nov 2018
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After a few damp squib tweets, HMRC has finally lit the fuse under the MTD communications by writing to all businesses within the scope of MTD for VAT.

The CIOT has confirmed the first ‘wave’ of 20,000 letters to affected businesses will hit doormats on Thursday this week, followed a further 180,000 to be issued next week. There are two versions being used to enable HMRC to monitor their performance.

Why the delay?

HMRC says it held off contacting businesses directly about MTD for VAT until the pilot was ready to accept VAT returns from those particular businesses. HMRC managers apparently believe that business owners would be eager to jump straight into the MTD pool without taking time to adjust their accounting systems or to train staff.   

Thus, HMRC’s communications policy around MTD is driven by which businesses can access the pilot. As the pilot is opened up to more categories of businesses, those organisations will receive a welcome to MTD letter from HMRC.

Who is in the pilot now?

The MTD for VAT pilot was initially accessible by invitation only to the simplest businesses: essentially sole-traders. In mid-October the pilot also opened up to single companies, covering up to 600,000 eligible businesses.

All those VAT registered businesses who can now join the pilot and who have annual turnover of £85,000 or more, should shortly receive a letter from HMRC explaining how they can start submitting VAT returns under MTD, and when this will become compulsory for them. Some VAT registered businesses with turnover just below the VAT threshold will also receive the same letter.

Who is outside the pilot?

The following categories of VAT traders can’t join the MTD pilot yet, so won’t receive a MTD welcome letter from HMRC:

  • partnerships
  • trade with the EU
  • in a VAT group
  • VAT division
  • based overseas
  • use VAT flat rate scheme
  • make VAT payments on account
  • newly registered and haven’t submitted a VAT return yet
  • in the surcharge system.

Extension of the pilot

HMRC expects to start private testing the MTD for VAT system with partnerships and businesses who trade with the EU in late 2018. A selected few businesses from these categories will be invited to join the MTD for VAT pilot at that time. If those private tests run smoothly, the MTD pilot program will be opened up to all partnerships and EU trading businesses in early 2019.

Also in late 2018 or early 2019 the MTD pilot will be opened up to newly registered traders, those who use the flat rate scheme, and businesses within the surcharge mechanism. 

April 2019

MTD for VAT is mandated for all VAT registered businesses except those who have been deferred and those who qualify for an exemption on turnover or other grounds, for VAT periods beginning on and after 1 April 2019. The requirement to keep digital records starts from this date but the first VAT return, for a normal quarterly period, must be submitted by 7 August 2019.

We expect the MTD for VAT pilot to be opened around this time for the following VAT registered organisations who have been deferred: 

  • Trusts
  • Unincorporated not for profit organisations
  • VAT divisions
  • VAT groups
  • Public sector entities and companies
  • Local authorities
  • Traders based overseas
  • Large businesses who must make VAT payments on account
  • Annual accounting scheme users

These organisations should receive a welcome to MTD letter at this time

Exemptions

All businesses currently exempt from online filing for VAT will automatically be exempt from MTD for VAT, and they won’t have to apply for a separate exemption. This is a tiny number of VAT registered traders.

HMRC is expecting a small increase in the numbers of businesses who will qualify as exempt from MTD for VAT on the basis of disability, age, religion, or digital exclusion. These businesses will have to apply for an exemption from MTD.

The VAT Notice 700/22, para 2.2 says traders should contact the VAT helpline if they think they may be exempt, but that helpline has no information about the MTD exemption. HMRC will publish details of how to apply for an exemption for MTD at the end of November 2018, alongside new guidance, which HMRC hopes will reduce the numbers who will claim an exemption.    

Social media

HMRC will be running a social media campaign about MTD for VAT including twitter posts and YouTube videos. HMRC will also publish case studies of how businesses have converted to MTD filing of VAT returns, taken from real examples.

The HMRC webinars on MTD are available to view again under ”help and support for tax agents”, scroll right down under the online services heading to find the list of earlier webinars.

Replies (72)

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Replying to rosataylor:
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By patrickcb
07th Nov 2018 21:46

But I am thinking of my clients. I'm thinking of how much time and effort cloud accounting can save my clients. I'm thinking of the more accurate data my clients are producing, and I'm thinking of how I can advise them much better with real time information.

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Chris M
By mr. mischief
07th Nov 2018 18:15

Tornado posted:

"What happens if the XERO shareholders sell out to Chinese or Russian entities?"

This is a good point, but much more likely is that Xero simply goes bust. See my earlier posts on this subject. the balance sheet is a mess, they are still making losses and bleeding cash and the Finance Director is a wally.

They still have not listed their shares anywhere other than New Zealand, so not exactly a vote of confidence from the Xero board that they want to just stay on a second rate market.

So, what happens if Xero busts? The last 8 or 9 years has been very benign for the world economy for companies like Xero who aren't making any money and need to borrow shedloads of it.

If this was 2008 and not 2018 then Xero would be toast. And the subscribers would be praying that whichever bank moved in on Xero kept the servers switched on, or all their lovely graphs, charts and source data would be toast too.

For me HMRC has been utterly negligent in forcing through MTD at gunpoint without giving any consideration to this sort of issue.

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By the_fishmonger
07th Nov 2018 18:30

The idea behind MTD is fine. The reality, having moved over 3 dozen clients over onto four various cloud systems is that the vast majority are ill equipped to use this technology, no matter how 'simple' the cloud producers make it (apps on phones don't do much beyond the extreme basics btw).

The correction facilities on one are appalling (maintaining the old desktop problems, rather than starting with a fresh database). The reporting on two others leaves more than a bit to desire. Another has purchase/sales ledgers where you are unable to see a true activity log without running a report out of the browser. I could go on for hours!

None of the cloud systems have been designed to be used by volume transaction operatives (i.e. accountants and their bookkeepers), yet this is who will be forced to use them most.

Of course, the real issue here is that the old crusties at the institutes made no effort to engage with the Fintech Cos to push for a sensible working solution for MTD. The Fintechs were left to make up their own ideas and are now fleecing everyone with those sub-requirement products. Oh, and where they don't do something, "there's always a bolt on from XYZ" neglecting to mention it might be £150 per month!

It's a bit like the railway - no one is over-seeing and no one taking control

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Replying to the_fishmonger:
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By patrickcb
07th Nov 2018 21:42

I don't understand your comment "None of the cloud systems have been designed to be used by volume transaction operatives (i.e. accountants and their bookkeepers), yet this is who will be forced to use them most." I have clients who put through dozens of transactions into Xero each day and it works perfectly fine. Can you explain your comment?

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Morph
By kevinringer
08th Nov 2018 08:39

77% of my clients are partnerships so can't participate in the pilot but will be mandated from 1 April. 51% of my clients are either partially exempt or use a margin or retail scheme - none of the mainstream software can handle them. 81% of my clients are farmers - none of the mainstream software can handle farmers' averaging, herd basis etc, and most of my farmers are in locations where there is poor or zero internet. I'm no luddite - I've been filing digital tax returns since 1998, but I'm a realist and know the limitations of the software and my clients. I am QuickBooks accredited and have attempted to get a few of my more tech-savy clients to use QuickBooks but few have made progress. I would love it if all my clients had the time/ability to do their own bookkeeping but I know from 35 years' experience that they cannot.

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Replying to kevinringer:
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By patrickcb
08th Nov 2018 10:44

This is where the third-party apps come into play! I have several clients who are used car dealers and so are on the VAT margin scheme . As you say, none of the mainstream software can handle the margin scheme per se, but they can when you add on a third-party app. I found third-party apps that could handle the VAT margin scheme for clients using either Sage or Zero. There are farming third-party apps for Xero, so you might want to have a look at some of them.

Clients doing there own bookkeeping is a bit of a mixed bag for me: some clients seem to think they can learn bookkeeping in a few hours, others grab hold of the nearest barge pole and ask me to do the work. Irrespective, all of them can see the advantages of cloud accounting.

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Replying to patrickcb:
Morph
By kevinringer
08th Nov 2018 11:00

Thanks Patrick, I was unaware of these additional apps. Is there a list of them on HMRC? These might solve some of the problems, though I guess this is yet another app clients will have to learn and there will be extra cost?

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By North East Accountant
08th Nov 2018 09:12

At last, HMRC wakes up to start its communications to tell unsuspecting VAT registered businesses about MTD coming next April.

About time, we started communicating with our clients on 31st March 2016 and have done so periodically since.

It is such a shame that all the problems that will unfold in 2019 and beyond could have been properly resolved if only HMRC had actually listened to people who know what they are talking about.

We told them forcefully in September 2016 consultation trying to get millions through the starting gate all at once was a recipe for disaster but listen they did not.

We suggested they stage it like they did for AE but listen they did not.

HMRC you are about to reap what you sowed and you have no-one to blame but yourself.

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By djtax
08th Nov 2018 17:47

Its now Thursday - nothing in my post from HMRC. I'm gutted! ...but don't we all know that if HMRC 'issue' something on any given day then it won't arrive until at least a fortnight later!

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Replying to djtax:
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By johnjenkins
09th Nov 2018 09:34

Send them a reminder.

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By mcfinance
12th Nov 2018 10:56

I'm very pleased HMRC are moving towards the digital age, I welcome change.

However, I'm not impressed with the lack on information and I would have welcomed some webinars and support in preparation for April 2019.

Unfortunately, I'll be one of the many in a VAT group that will be forced to go live on MTD in May 2019 without time to plan and train.

I would be interested to see the contents of a letter anyone has received.

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Replying to mcfinance:
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By johnjenkins
12th Nov 2018 12:14

The letter will probably go something like.
"As from 1st April 2019 all business with a turnover of £85k or more who are registered for VAT will have to go onto MTD. To find out more please go on to our website and all the relevant details of how to apply and the software companies selling the equipment you will need will be available just as soon as we sort out a few slight problems.

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Replying to johnjenkins:
Morph
By kevinringer
12th Nov 2018 14:21

There are 2 versions of the letter. I have no idea why there are 2 or who will receive which version. Here are both versions:

Encouragement letters – version 1
The way you send us VAT information is changing – find out what it means for you
We are changing how businesses need to keep their VAT records and submit their VAT returns. This new service is known as Making Tax Digital. If you are a VAT registered business with annual taxable turnover above the VAT threshold (currently £85,000) you will need to use this service to report your VAT. This will be mandatory for periods starting on or after 1 April 2019, but you can make the switch now by following the guidance below.
To use this service you will need to keep digital records. This may mean using software designed for record-keeping or a combination of software packages or spreadsheets. You will then need to submit your return using software that works with Making Tax Digital.
By joining early you will know that your business is ready, but there are other benefits too. Going digital makes managing business finances easier. It can do this by making tax part of your day-to-day record-keeping in a way that will give you the confidence you’ve got things right. Once your software is set up and your VAT return is ready, it just takes the click of a button to send it to us.

What you need to do
To join the new service you can either:
talk to your accountant about Making Tax Digital and joining, if you have one
go to www.gov.uk and search for ‘MTD ready’ then click on the first link - this will tell you about the steps you need to take and give you the option to join
If you already use software to keep your VAT records, you need to make sure it has been updated to work with Making Tax Digital before you join.
If you need help, the link above includes short YouTube videos and help to find the best software for your needs. The pages also have links to the ways you can contact us to talk about Making Tax Digital.

This Encouragement letters - Version 2
We are modernising the VAT system - get your business ready now
For accounting periods starting on or after 1 April 2019, VAT registered businesses with an annual taxable turnover above the VAT threshold of £85,000 must:
keep digital records for all VAT transactions
use software to submit VAT returns to us digitally
We call this Making Tax Digital. If your business is VAT registered and has an annual taxable turnover above the VAT threshold, you should act now to get ready for this change.

What you need to do
To get your business ready, you must:
talk to your accountant, if you have one, about signing up to Making Tax Digital
go to www.gov.uk, search for ‘MTD Now’ and click on the first link to sign up
either
start using software to keep VAT records, if you don’t already
ask your software supplier if the software you already use is ready for
Making Tax Digital
Sign up now to be certain that your business meets the new requirements. Once your software is set up, you can send your VAT returns to us with just the click of a button.
Support is available on the link above. This includes short YouTube videos and help choosing the best software for your needs. The guidance pages also have links to the ways you can contact us.

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Replying to kevinringer:
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By johnjenkins
12th Nov 2018 15:23

I wasn't far wrong.

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Replying to kevinringer:
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By EnglishRose
13th Nov 2018 08:53

Thanks. Mine will probably come soon. I don't find either particularly helpful and I won't be watching any videos. So that really just brings me back to square one - learning how to use excel and finding the cheapest or free bridging software off the cloud which exists yet.

I am hoping whether paid or not it just takes a few minutes to download and install and that I will keep my paper/Word records in tandem in case it does not let me save all the detail and explanation I choose to write into my existing records.

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Replying to kevinringer:
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By djtax
13th Nov 2018 10:21

Kevin - thanks (how did you get your hands on these?) - neither I nor any of my clients have yet to receive the letter.

Isn't it jolly super that it all works by 'just the click of a button' - there was I thinking that more was involved.....

How many of us will be encouraging clients to register for MTDfVAT early I wonder....

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Replying to djtax:
Morph
By kevinringer
13th Nov 2018 12:16

I like 'By joining early you will know that your business is ready' as if that's all you have to do.

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Replying to kevinringer:
Morph
By kevinringer
13th Nov 2018 12:20

Both letters tell the business owners to contact their accountant. I'm glad HMRC are telling businesses this rather than doing it themselves. But by telling clients to contact us it implies we will have a quick solution for MTD. It'll be us who will have to give the client the bad news. With 39% of my clients still using paper records I'm going to be giving out a lot of bad news.

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Morph
By kevinringer
13th Nov 2018 09:17

Welsh Rates of Income Tax (WRIT) start 06/04/19. Tax rates won't be a change for 2019-20 because the Welsh Government is maintaining the 2018-19 rates. HMRC is in the process of writing to all Welsh taxpayers telling them about the change. Taxpayers receive a letter in English and Welsh, and a flyer in English and Welsh. WRIT is far less disruptive than MTD yet HMRC is sending more information to Welsh taxpayers than it is sending to businesses affected by MTD. It is almost as if HMRC is trying to ignore MTD in the hope it will go away.

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Replying to kevinringer:
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By djtax
13th Nov 2018 10:24

..as per my still held view that the Lord's committee's report, once issued, will have a significant impact on what happens next year.

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Replying to djtax:
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By david.bransbury
13th Nov 2018 10:59

I think you will very much disappointed if you think the HMRC is going to delay mandatory introduction of HMRC for VAT from April 2019 because of what the House of Lords committee says.

As someone who watched the HMRC being grilled by the committee I expect the report to be scathing but the committee can't even get Mel Stride to talk to them. Their concerns will be noted but nothing will happen.

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Replying to david.bransbury:
Tornado
By Tornado
13th Nov 2018 20:25

House of Lords Committee or not, there is no way that MTD for VAT will be mandatory from 1st April 2019.

We already have exceptions creeping in plus the new revelations that many Government Departments which account for VAT may be unable to comply with the regulations, along with thousands of larger businesses who have bespoke complex accounting systems that will also be unable to comply with the regulations.

The clear evidence is there for all of us to see that making MTD for VAT mandatory from April 2019 will be impossible to achieve.

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