Filing deadlines (P11D, PSA etc) and #COVID19 #coronavirus

P11D deadlines are looming

As a result of #coronavirus lockdown and increased home-working arrangements, many payroll and reward professionals are concerned with some of the rapidly arriving submission and distribution deadlines and whether they can be met.

Access to documentation, records, and interaction with benefit providers may be difficult! Ability to print forms and distribute to the workforce may be a challenge! Information required for filing with HMRC may be incomplete!

P11D filings are ordinarily required to be completed by 6th July with pay-over of associated Class 1A by 19th July (22nd electronically), and the PSA return required by the 5th July etc etc.

No general extension planned

HMRC policy have confirmed the following:

As a result of the queries we were receiving in respect of filing deadlines, we looked at whether there was any merit in HMRC adopting a policy to extend all filing deadlines in light of the COVID-19 crisis.

We decided not to do that and instead we are encouraging customers to file their returns on time if they are able to do so.

Where a customer is unable to file their returns on time, decision makers should apply any existing statutory discretion in the usual way, on case-by-case basis.

If a penalty has been issued for failure to meet a filing obligation, and statute provides that liability will not arise if there is a reasonable excuse, then HMRC will consider COVID-19 as a reasonable excuse for missing some tax obligations.

However, for HMRC to consider whether there is a reasonable excuse the customer must be able to explain how they were affected by COVID-19 and customers will still need to make a return as soon as they can. Further guidance can be found here: https://www.gov.uk/tax-appeals/reasonable-excuses.

The only slight exception to the above position is in respect of SAO returns, where we believe that if an extension is granted by Companies House then that extension will therefore also apply to the tax returns, otherwise we expect the usual time-limits will apply.

As you can see, we are encouraging customers to meet their tax obligations as normal unless there is a specific easement announced by the government. The following gov.uk guidance has been updated to cover COVID-19;

Tax appeals – reasonable excuses

If you’re affected by coronavirus (COVID-19)

HMRC will consider coronavirus as a reasonable excuse for missing some tax obligations (such as payments or filing dates).

Explain how you were affected by coronavirus in your appeal. You must still make the return or payment as soon as you can.

Tax appeals – decisions

Tax appeals – penalties

PAYadvice.UK 14/5/2020

https://www.gov.uk/tax-appeals/penalty

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