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RTI update: Is the system actually working?

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11th Mar 2015
Editor at large AccountingWEB
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With the passing of another year in the payroll calendar, questions are still being asked on AccountingWEB about why so many errors are arising around the data submitted via real time information (RTI) mechanisms. John Stokdyk investigates.

Nearly two years after mass implementation, RTI systems are still causing employers and their payroll agents problems:

  • Duplicated records continue to appear within the system, inflating liabilities for employers’ contributions and often triggering actions collection by agents working on behalf of HMRC’s Debt Management and Banking (DMB) team. HMRC told us this problem affects roughly 10% of employers within the system, with up to 75,000 individual entries needing to be corrected on a monthly basis.
  • Late filing notices continue to be issued, even though the adviser has electronic acknowledgements from HMRC
  • Reconciliation problems (detailed explanation)
  • HMRC tax codes and year end information doesn’t agree with the actual payroll deductions. “Car benefits missed, odd months’ payments to HMRC somewhere in the ether,” noted AccountingWEB member CLP.
  • Scheme closures - will this measure unintentionally affect annual schemes, and will HMRC notify the scheme operators beforehand?

When these issues have cropped up, AccountingWEB has asked HMRC to clarify the reasons for continuing errors in PAYE codes, disputed charges, reconciliation anomalies in the business tax dashboard and numerous other discrepancies.

The answers we have received have tended to be bland assurances along these lines:

  • Last month, HMRC acknowledged there have “always been cases where the employer's view and HMRC’s view of what is due are different”. In response, the department told AccountingWEB it is continuing to update its guidance and systems to reduce discrepancies.
  • Incorrect tax statements sent last October were not demands but merely tax summaries, it told us. “No one has been asked to hand a penny over in tax because of this.” The majority of the errors were due to employers failing to make final payment statements for 2013/14 tax year, so HMRC’s records were incomplete.
  • “We have always said we want returns not penalties,” HMRC said in September 2014. This is why it decided not to impose filing penalties during the first year of RTI (2013-14), and is the reason for subsequent delays on issuing automated penalties.

This time last year, HMRC’s director of personal tax Ruth Owen told us RTI was working well: “Our most recent figures show that over 96.9% of PAYE schemes are successfully reporting RTI which represents 99.7% of the PAYE population and 70% say that RTI is easy.”

Automated penalties themselves are a sure way to infuriate accountants and payroll agents. The roll-back of this regime and ongoing consultation around it is widely welcomed. But each time HMRC announces another change of stance on the automated penalties, the more likely it seems that all is not well with its RTI processing systems.

If every apparent episode of non-compliance carries the spectre of monthly fines ticking up on HMRC’s penalty clock, the prospects for HMRC and payroll practitioners is frightening. The tax department is clearly aware of the risk of alienating employers or their payroll providers by levying penalties that originate from problems within HMRC’s own systems.

Still uncertain about the underlying reasons and explanations surrounding the 16 February penalty announcements, we once again took members’ concerns to HMRC. This article includes its detailed responses on the duplicate records issue, but the department was less forthcoming with explanations for the reconciliation errors and incorrect late filing notices.

On the reconciliations issue, HMRC responded: “Please let us know what issues are being reported by AccountingWEB members and we will arrange for our specialists to look into them and provide relevant explanations.” Those seeking explanations should contact HMRC’s Employer or Agent helplines, it added.

When pressed on how many disputed charges have arisen from misallocations, the HMRC replied: “Without knowing what the issues are we are unable to answer this question.”

We also asked for HMRC to explain why problems appeared to be originating within its back end SAP accounts software and Enterprise Tax Management System (ETMP). Could it assure AccountingWEB members it was producing reliable figures?

“Yes. Our accounts are audited by NAO, who were also satisfied,” HMRC replied.

Business as usual?

Payroll lecturer and AccountingWEB contributor Kate Upcraft has been challenging HMRC’s view that RTI is now running in business as usual mode. From conversations with HMRC and DWP as part of her role in the original RTI stakeholders’ consultation group, Upcraft gained insights about what was happening within HMRC and reliability of data passing between the departments.

In her view, HMRC’s opaque answers about data discrepancies go back to one of the fundamental problems within the RTI computers, where reporting amended but accurate data confuses the system and causes duplicates to be created. These in turn increase employers’ liabilities, lead to incorrect tax codes being issued and set the debt machinery in motion.

It doesn’t help, Upcraft adds, that “DMB have traditionally worked independently within HMRC so did not attend the RTI Customer User Group regularly to share their plans for a new accounting system to go live alongside RTI”. When asked why the figures that employers have submitted don’t match those on their business tax dashboard, her contacts report being told on numerous occasions, “Don’t bother looking, it doesn’t make sense,” by HMRC helpline staff, who admit to cutting and pasting data from online files.

A year ago Ruth Owen told AccountingWEB that 420,000 duplicate records had built up within the system, but it was able to filter these down automatically to 20,000 by year end.

In June 2014 HMRC enhanced the tools that automatically identify and correct duplicate employments before these become visible to customers. Since then, HMRC has corrected duplicate employments on 112,000 employer schemes and corrected 1.3m duplicate employments relating to 628,000 individuals. HMRC is currently correcting 14,000 employer schemes covering 65,000-75,000 individuals on a monthly basis.

Duplicate employments within the system which they have been unable to recover automatically. These are currently highlighted and corrected as part of their disputed charge work, HMRC said.

HMRC pointed to its guidance in the February 2015 Employer Bulletin (page 4) explaining steps that employers can take to help avoid sending information that may lead to the creation of duplicate records.  Kate Upcraft moans about amendments causing errors.

HMRC added: “Employer Bulletin [52] covers the common errors that create duplicates, including where employers want to send HMRC amended information or information missing from the original submission.  It is provision of missing/additional information (often start and end dates) that causes problems. HMRC does, of course, want employers to provide them with correct information on the original submission.  If the employers subsequently realise that they have made an error they should follow the guidance in the Employer Bulletin as submitting the missing/ amended later could create duplicates.”

The duplicates originate within HMRC’s National insurance and PAYE system that receives earnings data from the core RTI database, but according to Upcraft its new back-end accounting system is also introducing inexplicable charges: credits for no obvious reason; recoveries of statutory payments added in rather than deducted; payments duplicated on accounts; and the system’s in-built logic that reallocates payments to earliest outstanding period rather than the period to which the payment relates without communicating this action to the employer/agent.

This brings us to a parallel argument that has been taking place in Whitehall and beyond about the role of the BACS payment network within RTI.

Verifiable earnings data is vital to the universal credit system, so most of those involved in the process are concerned about what will happen if employees do not receive the amount of UC they are expecting - and where they will go to get their queries answered. Civil servants certainly don’t want to field all those calls, which is why the issue has become such a political hot potato.

And employers or their payroll service providers will probably end up having to clean up any mess.

The latest episode in this discussion took place in Parliament at the end of February, when DWP minister Mark Harper answered a question from Stephen Timms MP about how earnings data is validated for universal credit calculations “which do not require employees to contact their employer”.

The minister answered: “DWP uses earnings data received from HMRC’s PAYE Real Time Information system - much of which will have been received by HMRC in validated form from employers who use the Bacs payment system to corroborate their submissions against real payments.”

In its answers to AccountingWEB HMRC played down the significance of hashing saying it makes no difference how employers pay their employees.

“When someone claims universal credit their identity is validated and checked against DWP and HMRC systems,” the tax department said. “If these match, a flag appears on our system and any RTI received is sent to DWP within six hours of receipt at HMRC. Where the hash has been provided HMRC tells DWP whether the RTI amount is fully hash-matched, partially matched, or not matched. HMRC also tells DWP when no hash is provided.”

According to Upcraft’s sources, HMRC currently attaches a confidence level to earnings data passed to DWP. The scale ranges from 1 (hash and amount match) down to 5 (payment not confirmed). Confidence levels 1 and 2 are the only ones that can be attributed to BACS submissions supplied with a service user number.

After two years wrestling with these issues, Kate Upcraft now favours the RTI-Bacs approach: “Employers and agents should take heed of the guidance that HMRC published in the December Employer Bulletin that using direct/indirect Bacs with an individual service user number means that where the hash generated in the Bacs system and hash in the FPS matches - as it should in the vast majority of cases - DWP has certainty that the employee received those earnings.”

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Replies (22)

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By MJ Green Accountancy
11th Mar 2015 12:15

This is a very timely article, I was just this morning going to post a question in "any answers" regarding RTI, I was beginning to wonder whether my practice was alone with this issue.

 

RTI in theory is a good idea, in reality it doesn't really work.

 

We have recently had a client in tears after having spoken to an HMRC employee who was very sharp with her. One of my employees then spoke to someone at HMRC regarding the same issue and was treated in a very abrupt manner.

 

Only yesterday the same employee spoke to an HMRC member of staff regarding tax that HMRC believed was due (and it was subsequently proved that it wasn't) and after HMRC provided the staff member with details of what they believed to be correct stated that if the tax wasn't paid in 7 days a debt collector would be appointed.

 

We have had issues where P45's that have been submitted have apparently not shown up on HMRC's system.

 

A few clients have had staff members where they are taxed on having two jobs incorrectly, again because of P45's that apparently seem to have been lost.

 

Recently, a client paid himself a bonus. He then received a new PAYE coding notice stating that all of his personal allowance had been removed as HMRC believed he would earn over £100,000 in the current tax year. Even with the bonus, he would be nowhere near.

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By D G PRIEST
11th Mar 2015 12:35

RTI

After spending an hour and a half trying to sort out a over payment notice that was received for one of our clients it is obvious that a the staff on the helpline are struggling to handle the volume of calls that are being made is some cases they do not understand there own system so what chance have we got.  When you are then told it could be your own software at fault.We run a payroll service  for a number of customers and this has only happened to one or two so that was a lame excuse.  They could not give me any explanation as to why their figures for two pay periods were different to what had been submitted.  We were told this would be passed to another department that deals with these issues and it could take 3 months to be resolved. What is worrying is on the notification they tell you to reduce you next payment to them if you think you have over payed those payroll providers and accountants understand how the system works but people who try to do this themselves could be caught out.  Its time that they got their act together and stop putting the burden of their short comings on accountants, payroll providers and expected the client to pick up the bill or do they expect us to do it for nothing. 

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7om
By Tom 7000
11th Mar 2015 12:36

3%

Theres always going to be 3% that doesnt work just like

 

Unemployment

tax return season and clients who dont turn up

staff attendance

bad debts

and the list goes on and on

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By knowes
11th Mar 2015 13:00

Demand notice

I first had a demand notice in October for alleged unpaid tax and nI.  Telephone conversations seemed to suggest that Revenue System was not recording submissions in correct periods.  We are very diligent in our weekly timing of RTI submissions.  I was advised matter would be referred to the Disputes Resolution Team.  Same problem arose in January.  Again, further calls and referral to DR Team, who have still not responded/acknowledged the first query.  At least I managed to persuade the IR that they should not be sending debt collectors!

Poor service and communication.

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By raybackler
11th Mar 2015 13:08

Knock on effect to Auto Enrolment

This week, I have dealt with a Pensions Regulator letter having a PAYE reference I have never heard of for a client.  This client was a sole trader and transferred his business to a limited company in 2001, yes 2001.  We have acted for them since 2005.  The PAYE reference pre-dates our involvement and may relate to the sole trader period, but the Pensions Regulator would not give me the name attached to the reference for Data Protection reasons, so I am in the dark.  The source of the Pensions Regulator's information is HMRC.  This may be an isolated case, but if the Pensions Regulator is being given defunct information, watch this space.

I had to send an email with as much as I know to the Customer Support line at the Pensions Regulator and I have not yet heard anything further yet.

Next I logged on to my PAYE Agent area at HMRC, to check if there was any sign of this reference.  There are two live limited company registered at the same address.  One has a payroll and one doesn't.  The one that doesn't still has a live PAYE reference, even though it is defunct and I have had no correspondence nor filed any PAYE year end returns for ten years.  I pointed this out on the email I sent the Pensions Regulator, but it wouldn't surprise me if this company was also issued with a staging date letter from the Pensions Regulator, based on the transferred HMRC information.

On the face of it HMRC have a lot of unreliable data that could find its way into other government departments regarding Universal Credit, for instance, as well as the Pensions Regulator.

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By Old Greying Accountant
11th Mar 2015 13:11

On the whole ...

... RTI has been fine for me, the only thing that needs looking at is the filing deadlines, if only they made them monthly by 5th of the next month for FPS and by 19th for EPS the system would be pretty good, now we are in penalties I think there will be choppy water ahead and much time wasted appealing penalties.

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Chris M
By mr. mischief
11th Mar 2015 13:32

It's in meltdown

I am going to stick to the facts as regards my own practice.  Because I could see what a mess RTI was going to be, I am "payroll light" only running 40, 32 of these have just 1 or 2 people on the payroll and none has more than 10.

1.  Out of around 20 notices of coding for 15-16 received, 3 contain ridiculous tax codes resulting from data from 11-12, 12-13 and 13-14 tax years on jobs the people concerned left in those tax years.

2.  I have had 3 debt management chasings in the past 12 months.  One of those was resolved within a week, it was my error for advising the client the wrong payment amount from the P32.  Both of the other 2 were HMRC's fault.  One took 4 months to resolve and one 3 months.

3.  On three separate clients HMRC has denied receiving EPS submissions showing the EA indicator set to yes.  HMRC have denied receiving these even after having been sent PDFs by me showing what I had sent and the electronic acceptance of these by their database.  Rather than carry on with such an illogical argument, I just blanketed the system with EPS submissions and now hope for the best when they add up their sums at year end.

4.  Being in the North West I have made 6 claims across 3 clients in earlier tax years for NI holidays, the forerunner of the EA.  Two of these claims were not processed properly by HMRC despite being sent the supporting information in writing 3 times in each case.  Both of these cases took 12 months to get out of Debt Management, only after using both the AAM teams and official Complaints and in one of them a successful Compensation Claim.  This fiasco is my big worry over EA.

That's just off the top of my head.  If I looked through the records I could find more.  Much of it comes down to HMRC incompetence one way or another.

 

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By P2
11th Mar 2015 14:16

P45s

We too have had issues where we have prepared the leaver details on the HMRC software and then been unable to access the P45 after the monthly payroll has been submitted.

Going to the individual employees page, the left hand panel shows there are (0) outstanding submissions and yet the access box to the P45 is blank and the narrative to the left of the box reads "unsubmitted".  Very odd.

This is a particular worry even now as HMRC are now issuing P9s for 2015-2016 for people who left our employment in April 2014!! 

Grateful for anyone who has also experienced this problem, has solved it and can give me a work around.

Best wishes all,

P2

 

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ghm
By TaxTeddy
11th Mar 2015 15:06

So - to answer the O/P question....

... for tax agents the system clearly isn't working well at all.

But I worry that the HMRC view might be different. Consider what HMRC actually want - they want to be able to report to their Treasury masters that x% of PAYE tax is reaching their bank account at the correct time and that arrears of tax (more of that later) are reduced.

On that basis they can report the system is working fine - because the money is rolling in as usual.

Logging the number of disputes and arguments with taxpayers and agents is probably way down their list of criteria to be measured.

So that leaves disputes.

We are still in the early days so the disputes are just starting to mount. If, as comments above suggest, the HMRC data is crap (actually we know it is, I'm just being polite) then the number of disputes will snowball over the next 12 months - particulary when penalties for micro payrolls kick in.

What then? Well, knowing HMRC as we do it's a safe bet they will throw no more resources at the problem - it will be a blanket denial. This time next year I fully expect every one of us will be caught in the middle of a handful of penalty and other RTI disputes which are going nowhere.

Anyone on a Working Together committee should flag this now and apply as much pressure as they can before it becomes serious.

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By malcolmhUK
11th Mar 2015 15:48

It isn't working well from our point of view

High proportion of issued 2015/15 coding notices are incorrect with many showing earnings over 100k - total rubbish !

Calls taking 30 - 40 minutes to get through to Employers helpline and E-desk services.  Slightly less for Debt Management but they just want no money and deny any responsibility for any HMRC error.

Submissions leaving here get changed when they get to HMRC records - 5 we know of.  CIS makes the whole thing worse !  Initial answer by HMRC is to blame us until you can get the breakdown and pin it to a particular period and then go to the Employers Helpline to raise the matter with the disputed charges team.  

Dashboard a total waste of time often offering a different version from us and HMRC !  HMRC staff say that we should not rely on it being accurate - sad !  Often very difficult to get HMRC to give us their figures to find differences.

Use Agent Account Managers ?  Found it to be a very long winded affair and then being left hanging waiting for someone to reply.  Just asking for the detail of filings held by HMRC took over 2 months via AAM recently.  Not good when Debt Management are still chasing the money.

Just off to write to my MP.  Following up a letter I wrote a year ago when I was assured all was improving within HMRC. 

 

 

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By Robert Hurn
11th Mar 2015 15:55

Does the Online Help team Actually Exist?

I took over a payroll last year that requires an Earlier Year Update (EYU) to correct data filed at 2014 year-end.  HMRC insist that this can be done online but I cannot see the option on my dashboard.  I have phoned the helpline numerous times over the past week, holding for very long periods of time.  It doesn't matter what time of day or night I call they simply never answer the phone.  Sage Payroll doesn't appear able to file the EYU as it requires a negative adjustment.  Meanwhile HMRC threaten to recommence collection action for alleged payroll debts that they know to be inaccurate.

I fear that I will be forced to join the growing trend of outsourcing payroll as the time being employed managing the various issues that contributors have mentioned above can't normally be billed to the client but is taking a large number of hours out of my working week.  But I wonder whether payroll bureaus will be able to serve small 1-5 employee companies at an affordable rate and even if they can the coding and inaccurate demands for payment from HMRC are likely to land on my desk

It's hard to think of a bigger business deterrent than RTI - HMRC appear to enjoy the new powers it gives them to demand that the employer undertakes work on their behalf, often to correct their own failings.

If the Government really want small business to thrive then RTI must go

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Chris M
By mr. mischief
11th Mar 2015 16:00

Compensation claims

In my view as a profession we should pursue Compensation Claims with the utmost vigour.  This is one message HMRC will listen to - the only one, in my view!

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By Robert Hurn
11th Mar 2015 16:27

Government E-Petition???
Perhaps AW users could agree the wording for an online petition to have RTI rolled back, scrapped or whatever the consensus is. My view is that is should be voluntary for small business, many would continue using it – but all should have a paper option for items such as Earlier Year Updates which are proving problematic. The claim that RTI is needed for Universal Credit has lost all creditability, thus I would question what purpose RTI is servicing.
If we can get 100,000 signatures it must be considered for debate. Might be an embarrassment the Government would like to avoid before the election

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By Sandra Silk
11th Mar 2015 23:08

RTI is straightforward but has created more issues to sort out

Its good to know others have the same problems with HMRC as we are having.

RTI, whilst straightforward for submissions, seems to have created more issues that we need to sort out with HMRC.  For example Debt Management chasing debt when overpayments are "hidden" within previous year information which is shown as Not Available on the dashboard and submissions being inaccurately recorded which is apparently our fault for sending the wrong information. Allocation of payments is often impossible to unravel - I don't know why they have to split a payment over several different months.

I sent a letter of complaint to HMRC in January because I had had no response to several letters written since February 2014 about an overpayment of PAYE sitting unallocated on a client account whilst Debt Management harassed them several times for unpaid PAYE. Its now March and I have still not received a reply.  When HMRC do respond by letter they give 14 days for us to respond but they can't deal with anything in 14 days.

I don't envy HMRC staff having to work in an environment where every phone call they receive is from someone complaining about an error, but HMRC need to make the process of sorting out their errors quicker and easier for payroll providers and employers.  None of us have loads of time to ring HMRC and hang on with no indication how long you will have to wait to be answered.  

And why can't HMRC acknowledge 64-8s?  To be told you are not registered as an agent and they can't talk to you when you have been holding on the phone for ages is worse.  We have had this happen a number of times and its only when you phone HMRC to sort something out you find they have never actioned the form you sent months or even years ago.  They tell us that they never received it but we always send the 64-8 in the same envelope as FBI2 and that is always actioned.

 

 

 

 

 

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By Jekyll and Hyde
12th Mar 2015 07:40

for the clients that understand then yes, it works reasonably we

For the clients that have no business knowledge and skill, who purely want to do what they do what they do (non businesses) then no And the burden is passed onto the agents.

We talk about whether the system Is working and I feel it is way too early to tell. A lot of micro traders will not have written up their 2014/15 books yet and will not pass these to the accountant for another 6 months or so. In the meantime they will have missed paid the eemployees and a who host of other issues that the accountant will find out about after the tax year has concluded. RTI will never work and it doesn't matter how !any accountants discuss RTI and Auto enrolment these client types simply do not understand.

I Went to see a potential new client on Monday. Small shop Ltd co under vat threshold with 1 employee and two directors. Simple, paying weekly payroll. Current accountant advised directors pay £250 per week and the client is using HMRC payroll. I took a quick look and I asked client what is being paid? 1 payment to cover a weekly pay and dividends for two directors going out of the bank each week. She told me the breakdown of what this is made up of. salary £250 x 2 and dividend x 2 £x. I look at the RTI submissions which clearly show net pay as £238.xx per week. Client genuinely didn't understand the difference with gross and net pay, let alone separate payments.

Is this the accountants fault? Possibly/possibly not. But as the accountant will only see the accounts information after the tax year end and the accounting year end then how is RTI ever going to work for these type clients. Yes education of client will help, and in the theritical world we can all educate clients to be expert business owners, however in the real world these micro clients are usually the lower profit clients with a limited amount of monetory resources available to pay the accountant and the accountant can't work for free for every client. Hence why they often do the DIY accounting jobs themselves!

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By North East Accountant
12th Mar 2015 08:46

What fun

RTI can work OK but when it doesn't it's a nightmare.

The light at the end of the tunnel is the Auto Enrolment train heading towards us.

AE will be such fun!

 

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Chris M
By mr. mischief
12th Mar 2015 15:02

Good points raised by Sandra.  In my view the key to success in these situations is:

1.  Ensure HMRC has no visibility of what is going on below the surface.

2.  Ensure the client has a written record from you about what will happen if HMRC gets that visibility.

It's a stupid system for these sorts of businesses to attempt to comply with, with potentially large penalties for being seen to not comply with it.

Therefore:

Be SEEN to comply!

 

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By raybackler
15th Mar 2015 22:44

Tax code errors for 2015-16

Just received a K code with 5 further digits, so the person is alleged to be on much more than £100000 per annum.  Actual income not even a problem for loss of child benefit (and never has been)!!

Tried to call HMRC having sent a paper 64-8 in December 2012 and, guess what, it hasn't been processed.  The 64-8 for his wife and his limited company have been processed and they were in the same envelope.

Applied for a PIN number online and then will get to the bottom of it in the next week or so.

 

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By raybackler
14th Mar 2015 23:11

Employment Allowance problems

I have had two HMRC requests for overdue PAYE payments in the last week or so.  Checking the figures, it seems that Employment Allowance may have not been processed, despite ticking the right box in the payroll software for both clients.  I checked this again before making this posting.  Anyone else had this problem?

I have applied for PIN numbers so I can look at the online accounts with HMRC.  I haven't had to worry with these two clients previously, as they have simple payrolls that until the Employment Allowance was introduced this year, never had to pay PAYE.

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Chris M
By mr. mischief
15th Mar 2015 10:41

Yes!

Yes raybackler I have encountered that problem now 3 times.  It seems to me there is a glitch in the HMRC system with regard to EA processing.  See my other posts on this subject.

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By Mike Nicholas
18th Mar 2015 10:59

What a mess!

I also have been told by an HMRC call centre operator to ignore the entries on the dashboard. To answer my query about a specified charge the operator looked at the actual entries held by HMRC which were different to those shown in the dashboard.

Specified charges arise where no RTI return (FPS or EPS) is submitted for the PAYE scheme for a tax month. Once on the system these SCs have the potential of causing mayhem in the dashboard, and HMRC's debt management department will pursue payment for it even though a payment made for the scheme will partly or fully extinguish the SC entry. Avoid SCs!

As regards UC, RTI and BACS, I'm in the HMRC camp with this. If it's ok for non-BACS payment to be passed to DWP and accepted for purposes of UC what makes a BACS-hashed supported RTI return better for UC purposes? Surely the RTI data in the FPS returns is what is important?

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By Robert Hurn
18th Mar 2015 11:19

Good News on Auto Enrolment

Just read in the Pension Regulators booklet "Automatic enrolment will be business as ussual just like RTI.... " That's a relief!

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