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Taxpayers asked to pay same simple assessment twice Photo of an HMRC envelope

Taxpayers asked to pay same simple assessment twice


Some taxpayers have been asked to pay the same tax bill twice after HMRC sent paper copies of simple assessments that had already been paid.

2nd May 2023
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The Institute of Chartered Accountants in England and Wales (ICAEW) Tax Faculty has raised concerns about HMRC issuing duplicate simple assessments to taxpayers, despite some having already paid the bill. 

The confusion started after HMRC sent taxpayers who opted for paperless communication a digital version of simple assessments through their personal tax account from May 2021 to July 2022. HMRC later put the brakes on this digital method after it became unclear whether it satisfied the legislative requirements. 

The tax authority then pressed ahead and sent paper versions of those simple assessments while the legislation was being updated. 

Simple assessments were given the all-clear to be served digitally from 6 April 2023, but in those intervening months, confusion spread. 

Confusion over duplicate assessments

The Tax Faculty explained that the re-serving of the document was to ensure the assessment had been validly served, but those taxpayers who had already settled the digital simple assessment were left confused by the duplicate assessments, which still listed the full amount. 

However, the paper assessment did include a footnote clarifying that “any payments made have not been included in the above calculation”. 

Taxpayers concerned about their payments found little support from HMRC contact-centre staff, who according to the Tax Faculty do not have access to the simple assessment payment system and had to pass these calls to a back-office team. 

Not so simple

Simple assessments were introduced in 2016/17 as a means to prevent taxpayers from being dragged into the self assessment system, or to allow them to be taken out of self assessment where HMRC has enough information to calculate the tax due. 

A simple assessment is a tax assessment made by HMRC rather than a self assessment made by the taxpayer. The paper version is delivered on form PA302, and it should only be sent when the tax liability can’t be collected via PAYE.  

The taxpayer then has 60 days to challenge the figures from the date of issue of the assessment. But this relatively new experiment of simple assessments has been far from simple for some taxpayers. The trials and tribulations around simple assessments have been well documented on AccountingWEB. 

In a post on Any Answers in 2020, AccountingWEB member Helpful Harry was told by HMRC that a major review of the simple assessment project in 2019/20 “threw up some anomalies”. 

So in response to the incorrect simple assessment, HMRC advised the agent to submit the self assessment tax return for 2019/20 so the client could get a refund, but answer “no” to the question asking if any underpayment has been included in the PAYE code. 

In another tale of woe in 2020, AccountingWEB regular Penelope Pitstop highlighted three simple assessments raised against one of their clients, and in each case HMRC got the bank interest wrong

Designed to confuse  

“This latest cock-up around the re-issuing of paper simple assessments, where the tax debt has already been paid, is yet another example of an HMRC project not being fully thought through before implementation,” commented AccountingWEB consultant tax editor Rebecca Cave.

We have seen this time and again when a new piece of the tax compliance mechanism is bolted onto the existing machinery, without working out how the two functions will mesh together. Other examples include:

  • the High Income Child Benefit Charge  
  • Real Time Assessments for capital gains tax (CGT)
  • the UK Property Account – assessing and paying CGT within 60 days
  • transferable marriage allowance.

Have your clients been asked to pay the same simple assessment twice? Let us know in the comments below.

Replies (6)

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By Catherine Newman
02nd May 2023 12:54

Another sign of HMRC not being fit for the purpose and digital by default failing.

Thanks (9)
By kevinringer
03rd May 2023 10:36

The duplicate Simple Assessment is the result of a change of policy, but HMRC have a long history of causing confusion without changing policy. Just look at SA302 which HMRC still insist on issuing every time they process a Marriage Allowance claim. Most clients think an SA302 is a bill and can get very distressed because the SA302 no longer shows payments on account already made. Indeed, sometimes the payments on account can result in an overpayment. I've lost count of the hours I've wasted having to explain to clients why the SA302 does not show the actual tax liabilities.

Though clients mistake SA302 for SA demands, HMRC don't make the actual SA demands any more comprehensible. HMRC has had over 25 years to make them more understandable, but they're as incomprehensible today as they were when they were launched. I sometimes wonder if HMRC go out of their way to make them as incomprehensible as possible.

Thanks (3)
Replying to kevinringer:
By Catherine Newman
03rd May 2023 12:51

I spend hours explaining them too. It is unhelpful to say "We have made amendments to your return". It looks as though we have cocked up.

Thanks (3)
Replying to kevinringer:
By richard thomas
03rd May 2023 17:33


The issue of duplicate simple assessment notices is not a simple (pun intended) or excusable change of policy – had it been there would have been no need to issue the paper form.

Richard’s post links to the ICAEW website and reflects what is said there:

“Between May 2021 and July 2022, taxpayers who had opted for paperless communications from HMRC received their simple assessments (PA302) digitally via their personal tax account.

It was not clear that this digital notification satisfied the legislative requirements. This has now been rectified. From 6 April 2023, simple assessments can be served digitally.”

I assume this is what HMRC told the ICAEW and not their own view. I have already been in touch with HMRC about this and can tell you that it was crystal clear to me and must have been to HMRC that they had no legislative foundation whatsoever for issuing simple assessments electronically to a secure mailbox.

The Income and Corporation Taxes (Electronic Communications) Regulations 2003, as they stood in 2022 said:

“2 Scope of these Regulations

(1) These Regulations apply to--

(a) the delivery of information, to or by the Board, the delivery of which is authorised or required by or under--

(i) any provision of section 8, 8A, 8B, 9, 9ZA, 9ZB, 9A, 9B, 9C, 9D, 12AA, 12AAA, 12AB, 12ABA, 12ABB, 12AC, 12AD, 12AE, 28A, 28B, 28C, 30B, 59C, 59DA, 59E or 100 of the Management Act,

3 Use of electronic communications

(1) The Board may only use electronic communications in connection with the matters referred to in regulation 2(1) if—

(a) the recipient has indicated that he consents to the Board using electronic communications in connection with those matters; and

(b) the Board have not been informed that that consent has been withdrawn.”

Note that the list does not include sections 28H, 28I and 28J TMA, so it cannot be the case that it was possible to do what HMRC did. The notices were therefore not delivered to the taxpayers and no proceedings could be taken by HMRC in relation to them.

The change made was a legislative one. The Income and Corporation Taxes (Electronic Communications) (Amendment) Regulations 2023, coming into force on 6 April 2023 added sections 28H, 28I and 28J to the list in regulation 2(1)(a)(i) of the 2003 Regulations. So by saying that HMRC “can” be served digitally from that date HMRC are giving the game away – it means that before 6 April 2023 they could not in law, not that it was unclear whether they could or not.

The Explanatory Memorandum to the 2023 Regulations repeats the untruth:

“Why is it being changed?

7.3 The Income and Corporation Taxes (Electronic Communications) Regulations 2003 did not clearly stipulate that Notices of Simple Assessment and Notices of Daily Penalties can be digitally made, delivered and (where appropriate) formally withdrawn. In order to support those who wish to receive such communications digitally from HMRC, this Statutory Instrument will amend the 2003 Regulations so that they apply to Notices of Simple, and other Assessments, withdrawals of Simple Assessments and Notices of Daily Penalties.”

Despite my emailing the person whose name and email address is given at the end of the EM, HMRC refuse to change the EM or enter into any correspondence, so I am contemplating a complaint and a FOIA request.

And that is not all of the problems with the regulation and the EM. They slipped in a new reference to s 30A TMA which covers all assessments which are not self-assessments. But there is absolutely nothing in the EM which covers this extension.

They also included a reference to paragraph 4 Schedule 55 FA 2009 (daily penalties for failure to file a return). This can only in the context refer to the notice that is required under paragraph 4(1)(c) of that Schedule, as assessments of penalties were already covered. But the EM does not seem to know the difference and is wholly misleading.

This I am afraid is par for the course with HMRC now. The amount of backside covering and failure to admit any kind of error or to apologise is embarrassing for a former employee.

Note also that there is nothing in the regulations covering Schedule 2 FA 2019 (60-day CGT returns and assessments).

Thanks (2)
By indomitable
03rd May 2023 12:32

Almost everything to do with HMRC is not fit for purpose!

Just today trying to get a colleague access to all our clients on our agent account.

You would think there would be a tick box so that you could add all clients or one or three. NO you have to do it individually!

You would think there would be the name of the client next to their reference (UTR, PAYE) - NO! so you don't even know who the client is without going back and looking in your other systems

If you wanted to design a system that was completely and utterly substandard to the user here it is.

Thanks (5)
By seonaid anderson
03rd May 2023 14:22

"Simple assessments were given the all-clear to be served digitally from 6 April 2023"..
Is there a separate alert that one has been issued? Most of my clients do not check their tax account regularly.

Thanks (1)