Issue 125 of Agent Update
Published 21 November 2024
Technical updates and reminders
Developments and changes to legislation and allowances relating to UK tax including:
Tax
- claiming a repayment of import duty and VAT — new digital form (C285)
- using the payrolling benefits in kind service for agents
- Reporting Rules for Digital Platforms — first reports due 31 January 2025
- construction operations — traffic management
- publication of Tax Administration Framework Review documents
- Guidelines for Compliance — updates
- Basis Period reform — reporting profits on a tax year basis
- confirming plans to mandate the reporting of benefits in kind through payroll software from April 2026
- the Official Rate of Interest from 6 April 2025
- completing Self Assessment tax returns for student and postgraduate loan borrowers
Borders and Trade
- update on the new requirements for safety and security declarations
- update on Welsh Freeport special tax sites and 5-year extension to tax reliefs
Making tax Digital
HMRC Agent Services
- UK subsidy reporting arrangements for Climate Change Agreement scheme participants for calendar year 2023
- Self Assessment top tips for agents
- Spotlight 65 — General Data Protection Regulation provision used to reduce tax liability
- Spotlight 66 — Limited Liability Partnerships arrangements used to disguise employment income
- Where’s My Reply tool updates
- Raising standards in the tax advice market
- reminder — tell us your Agent Codes
- individuals who reside both in the UK and other countries — how to avoid errors on SA supplementary pages SA109 boxes 21 and 22
Agent online forum and engagement
Latest updates from the partnership between HMRC and the main agent representative bodies. Including:
- missing 2024 to 2025 PAYE code numbers — SA 46134
- 2022 to 2023 Returns delays — SA 47683
- Self Assessment repayments failing automation SA26245
- Digital signatures CGT24134
- Issues Overview Group Escalated Issues
- Agent Account Manager Service
- registering for the Agent Forum
Tax
Claiming a repayment of import duty and VAT — new digital form (C285)
As of Monday 4 November 2024, traders can use a new digital form to claim a repayment of import duty and VAT for declarations that previously required a print and post form.
Claims made using the print and post form will not be accepted after 8 January 2025.
Using the payrolling benefits in kind service for agents
Agents can register employment benefits, which will be taxed through their client’s payroll from 6 April 2025 onward, but registration must be done before this date.
The employer client can only start payrolling at the start of the tax year.
Benefits that can be payrolled include, but are not restricted to:
- car and car fuel
- mileage allowance and passenger payments
- vans
- van fuels
- private medical treatment or insurance
To payroll benefits in kind online you need to opt in to use the Employer Liabilities and Payments service. If you have not already done so, you can opt in by signing in to your HMRC online services for agents account and selecting ‘PAYE for employers’.
You must still submit P11Ds for the tax year 2024 to 2025 and 2025 to 2026 for any benefits and expenses that have not been payrolled.
Reporting Rules for Digital Platforms — first reports due 31 January 2025
Background
New rules effective from 1 January 2024 require digital platform (software that allows sellers to be connected to users to provide relevant services or the sale of goods) operators in the UK to collect and verify information about sellers using their platforms. Platform operators will be in scope of the new rules if they provide software that allows sellers to be connected to users for relevant services or the sale of goods.
Clients that are platform operators
Platform operators will have to report information of sellers who use their digital platform to HMRC. The first reports are due by 31 January 2025. They also must provide sellers with a copy of the information reported to HMRC by the same deadline.
As an agent, if you have any clients that are platform operators and you need to report for them, you must use your own individual or organisation Government Gateway login credentials. You must not sign in with your agent services credentials, or the credentials of the digital platform you are reporting for. Once registered, you can add the details of your clients, where you will be given a unique platform operator ID for each one. This platform operator ID is required to make an XML submission for that platform.
Visit GOV.UK to find more information about the reporting rules for digital platforms.
Clients that are sellers on platforms
If any of your clients sell goods or services online, they will receive information from platform operators about sales they have made for the previous calendar year. If your client has sold goods or services on a platform, for example driving a cab or renting property, and has not paid the correct amount of tax, work with them to put it right.
For your clients that sell goods, the information will only be shared if they sell 30 or more goods or earn approximately £1700 or more in a calendar year.
Visit GOV.UK to find more information about selling goods or service on a digital platform.
Construction operations — traffic management
In response to the consultation Construction Industry Scheme (CIS) reform, proposing compliance and simplification changes to the CIS, respondents raised concerns regarding the scope of the CIS in relation to traffic management works. Those concerns are detailed in the Summary of Responses, published in the 2023 Autumn Statement.
Having considered those concerns, guidance has been published, which will supersede our previous rulings or clearances provided by HMRC. It provides clarification on the treatment of traffic management works for the purposes of the CIS.
From 1 March 2025, the provision of traffic management services will only be within the scheme if supplied to a contractor carrying out construction operations, except where it relates to supply only. It is regarded as being either preparatory or integral to the road works or construction operations and therefore subject to the CIS.
If you are unaware of this, contact us by email constructionforum@hmrc.gov.uk.
Publication of Tax Administration Framework Review documents
The government has announced the next stages of modernising and reforming HMRC’s tax administration framework:
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a summary of responses to the spring 2024 call for evidence on HMRC’s enquiry and assessment powers, penalties and safeguards
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an announcement to consult, in spring 2025, on ‘making better use of third-party data’ that builds on the Tax Administration Framework Review (TAFR) information and data call for evidence
The consultation on new ways to tackle non-compliance, invites views on HMRC’s approach to correcting taxpayer inaccuracies in a claim or return, and whether there are ways this could be improved.
Further consultations will follow in spring 2025 on:
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simplifying and improving HMRC’s use of behavioural penalties
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improving access to Alternative Dispute Resolution and Statutory Review
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modernising HMRC’s approach to acquiring and using third party data to make it easier for taxpayers to get tax right first time
Guidelines for Compliance — updates
Guidelines for Compliance are a suite of products for businesses and their advisors and makes clear our view on complex, widely misunderstood, or novel areas of the tax rules. They may apply to any tax or duty administered by HMRC, or to an issue that involves more than one tax or duty.
Guidelines for Compliance are part of HMRC’s ongoing commitment to publishing practical support for customers.
These are a few of the updates recently published:
Help to avoid errors in claims for plant and machinery allowances — GfC 5
HMRC have found some areas where there is a particular risk a plant and machinery claim may be inaccurate. We want to share information to help you manage those risks so that you get claims right and avoid unnecessary contact with HMRC.
These guidelines contain:
- information on common areas of error in claims for plant and machinery allowances
- a recommended approach to claims and record keeping
Guidance on Help to avoid errors in claims for plant and machinery allowances has been published on GOV.UK.
We aim to update these guidelines as new areas of risk are identified.
Help with patent box computations — GfC 9
HMRC found that some companies who elect into the Patent Box do not include enough detail in their tax computation. This leads to compliance checks that are often resolved when we see the missing detail. HMRC has also found common areas where errors can occur in Patent Box computations.
These Guidelines for Compliance are designed to share:
- best practice information to include in the tax computation
- areas where we see error in patent box computations
- best practice record keeping for patent box
- points of contact if there is doubt of how to apply these guidelines to a particular company
We want to share this information to help you manage risks associated with Patent Box computations.
HMRC has published Guidelines for Compliance (GfC), Help with Patent Box computations.
The Patent Box is designed to encourage companies to keep and commercialise intellectual property in the UK. It allows a company to apply a lower rate of Corporation Tax to profits earned from its patented inventions. The Patent Box is only available if you are within the charge to Corporation Tax.
Help with the Apprenticeship Levy and Employment Allowance — connected entities GfC10
HMRC has recently published new Guidelines for Compliance — Help with the Apprenticeship Levy and Employment Allowance — connected entities — GfC10
The term ‘entity’ includes companies, charities and public bodies (and their related organisations).
These guidelines clarify the connected entities rules to help employers correctly report the Apprenticeship Levy and claim Employment Allowance by:
- explaining how the connected entities rules impact the Apprenticeship Levy and Employment Allowance
- highlighting the common errors employers make
- giving practical advice on how to identify connected entities
- providing help on the unique scenarios in the public body population
- setting out how employers can correct any errors made
The guidelines are a practical product for customers to refer to and should be read alongside HMRC’s existing guidance. They will be updated as necessary to maintain their relevance and usefulness to customers.
More information, including other publications on Guidelines for Compliance can be found on GOV.UK.
Basis Period reform — reporting profits on a tax year basis
All sole traders and partners must report their business profits on a tax year basis, beginning with the Self Assessment return due by 31 January 2026 (covering the tax year 2024 to 2025).
The tax year 2023 to 2024 was a transitional year. For that year, any business that previously had a non-tax year accounting period must declare profits from the end of their basis period in 2022 to 2023 up to 5 April 2024. Any profits after the first 12 months up to 5 April 2024 will be treated as transition profit, with relief for any brought forward overlap profits available. The transition profit (less overlap relief) is spread by default over 5 years including 2023 to 2024 but can be accelerated by election or if the business ceases. Accounting periods ending on 31 March will now be treated as equivalent to those ending on 5 April. This also applies to property businesses.
Many customers may find it easier to prepare accounts to 31 March or 5 April from 2024 onwards. This may make completing the tax return simpler as there will be no need to use 2 sets of accounts to complete each tax return. Businesses remain free to choose their accounting date, and they can prepare accounts to any date in the year, but any business that continues to have a non-tax year accounting period after 5 April 2024 will need to apportion profits from 2 accounting periods to the tax year.
We have launched an updated package of online interactive guidance (which now also supports individuals reporting trading income from a partnership) to support completion of the return and working out transition profit for these cases.
We have provided an online service to ask HMRC what the overlap relief figure is according to our records.
To help us reply to as many as possible in good time to file the tax returns by 31 January 2025, please submit requests for overlap relief early and preferably by 31 December 2024.
If you have applied for this information and have not heard back, you can check the progress of your request. To make sure you meet the filing deadline, file with a ‘provisional figure’ for overlap relief and amend it when confirmation is received from HMRC.
Do not call us to request an overlap relief figure, as this can slow down our response times for all.
You can help us by only using the online form if you do not have a figure for overlap relief. The form is not intended to be used to check or confirm a figure that you already hold and there is no requirement to use the service before filing a return.
Customers can find more guidance and support for basis period reform on GOV.UK.
Confirming plans to mandate the reporting of benefits in kind through payroll software from April 2026
At Autumn Budget, the government announced some updates to the January 2024 proposals to mandate the reporting of benefits in kind through payroll software from April 2026.
The main adjustments we have made are:
- mandatory reporting of benefits in kind (BiKs) in real time, through payroll software, will be introduced in a phased approach from April 2026 — employers will be required to payroll most benefits from April 2026, but will not be required to payroll loans and accommodation at that time
- employers will be able to report employment related loans and accommodation through payroll software on a voluntary basis from April 2026 — a modified P11D and P11D(b) will be available to report just loans and accommodation if employers do not wish to payroll these
- no decision has been made as to when we will mandate the reporting of loans and accommodation through payroll software — careful consideration will be given to make sure sufficient notice of any change will be provided
- an end of year process will be introduced to amend the taxable values of any BiKs that cannot be determined during the tax year, however, we expect the taxable values of most BiKs to be reported as accurately as possible during the tax year
- the requirement to submit P46 (Car) forms will be removed as functionality will be provided to report the data required through payroll software in real time
We will continue to work with stakeholders to make sure that the mandatory reporting of BiKs through payroll software works for both HMRC and taxpayers. We will provide updates on plans to publish draft legislation and technical specifications.
The Official Rate of Interest from 6 April 2025
The Official Rate of Interest (ORI) is used to calculate the Income Tax charge on the benefit of employment-related loans and the taxable benefit of some employment related living accommodation. The government announced at Budget that the previous public commitment, made in January 2000 to not increase the rate during the tax year, will no longer be applicable. As of 6 April 2025, the ORI may increase, decrease, or be maintained throughout the year.
The rate will continue to be reviewed on a quarterly basis. Any changes in the rate will occur following a quarterly review, where appropriate. If there are any in-year changes to the rate, these will take effect on 6 July, 6 October and 6 January. Any future changes to the interest rate will be published on GOV.UK.
This change will increase fairness across the tax system by enabling the ORI to increase in-year where appropriate, ensuring employment-related beneficial loans and living accommodation are correctly valued.
Further information can be found at Autumn Budget 2024 — overview of tax legislation and rates (OOTLAR).
How agents can support employers
If you are responsible for the tax affairs of any employer that provides employment-related loans or living accommodation to their employees, you and your client will need to remain aware of any future changes in the rate. As of 6 April 2025, the rate may increase in-year which will impact the taxable value of the benefits the employer provides.
Completing Self Assessment tax returns for student and postgraduate loan borrowers
If you are completing a Self Assessment tax return on behalf of a client with an outstanding student or postgraduate loan, it is important that the Pay As You Earn (PAYE) income for each employment is included on your client’s tax return prior to submission to HMRC.
This ensures that charges relating to student or postgraduate loans are correctly calculated based on total income, and that interest is calculated at the correct rate by the Student Loans Company.
Student and postgraduate loan deductions taken from each employment must also be included in the tax return. These amounts will automatically be deducted from the total student or postgraduate loan charge in Self Assessment, as these deductions have already been sent to the Student Loans Company and applied to your client’s loan balance for the relevant tax year.
Further guidance on telling HMRC about a student loan is available on GOV.UK.
Update on the new requirements for safety and security declarations
Following the announcement that safety and security (S&S) declarations for EU imports will be introduced on 31 January 2025, we have published detailed safety and security guidance with information on the steps businesses can take to prepare on GOV.UK.
S&S declarations support the fight against illicit goods such as drugs and weapons entering the UK and make sure legitimate goods are not stopped for unnecessary checks.
We recognise that some businesses will be ready to start submitting declarations for EU imports earlier than 31 January — for example, because they already submit declarations for rest of the world (RoW) imports. Those who are ready to start submitting their declarations ahead of this date are welcome to do so.
We will continue to update the guidance on GOV.UK on how to use the S&S GB service if you import goods into Great Britain and need to make an entry summary declaration in the coming weeks to support readiness activity.
Update on Welsh Freeport special tax sites and 5-year extension to tax reliefs
The first Freeport special tax sites in Wales have recently been confirmed at Celtic Freeport. These sites, which are due to be designated from 26 November 2024, are in addition to the existing 30 special tax sites throughout Freeports in England and Scotland.
In May 2024, legislation was laid to extend the time available to claim Freeport tax reliefs from 5 to 10 years. Eligible businesses within a special tax site can claim the available tax reliefs from the date the site is designated until 30 September 2031 in English Freeports, and 30 September 2034 in Scottish Green Freeports and Welsh Freeports.
For more information on claiming the available tax reliefs, see the following guidance and check if you can claim:
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Relief from Stamp Duty Land Tax in a Freeport or Investment Zone special tax site in England
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National Insurance relief in UK Freeport or Investment Zone special tax sites
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Enhanced capital allowance relief in UK Freeport or Investment Zone special tax sites
You can find more information about Freeports on GOV.UK, including some useful resources and examples showing how businesses can benefit from the tax reliefs available in a Freeport.
Making Tax Digital
MTD for Income Tax event for agents
As part of Making Tax Digital (MTD) for Income Tax, sole traders and landlords with income from self-employment and property over £50,000 will be required to keep digital records from April 2026. They will also need to send quarterly updates to HMRC using compatible software. Those with a total income from self-employment and property that is over £30,000 will need to follow this process from April 2027.
Sole traders and landlords whose income from these sources that is over £20,000 will be required to use MTD for Income Tax from a later start date. This date will be confirmed by the government at a future fiscal event.
To help you and your clients prepare for this change, HMRC is hosting an MTD for Income Tax event at our Croydon Regional Centre office from 11.00am to 3.00pm on Thursday 5 December 2024.
This event is intended to help accountants, bookkeepers and software developers prepare for the introduction of MTD for Income Tax from April 2026.
At the event you will:
- find out more about the testing phase for MTD for Income Tax, including the extra support on offer
- have access to hands-on support to signing up for testing
- be able to ask HMRC colleagues your questions about MTD
How to sign up
This event has limited spaces, so if you have clients who are eligible and ready to join the MTD testing phase, email mailbox makingtaxdigital@hmrc.gov.uk no later than 29 November 2024 to secure your place.
HMRC will be hosting more MTD events across the UK from February 2025. We will share dates and locations for these upcoming events in future editions of the Agent Update.
HMRC Agent Services
UK subsidy reporting arrangements for Climate Change Agreement scheme participants for calendar year 2023
HMRC is required to collect data from Climate Change Agreement (CCA) scheme participants whose annual tax subsidy benefit is above a defined threshold.
The threshold for reporting subsidy information is over £100,000.
Businesses registered in Northern Ireland trading in goods or the wholesale electricity market will need to report their annual CCA subsidy award if it exceeds £86,994. Find more information about complying with the UK’s international obligations on subsidy control.
In October, HMRC launched a data collection exercise for the reporting period between 1 January2023 and 31 December 2023. UK businesses are now required to report CCA subsidy information to HMRC through an online form on GOV.UK.
This data will be published showing all subsidy awards above the reporting thresholds to promote accountability and transparency.
Businesses who receive an annual tax subsidy award exceeding the reporting thresholds for calendar year 2023, must complete the online form available in the Climate Change Levy subsidies guide by 31 January 2025.
Self Assessment top tips for tax agents
Here are some top tips for tax agents ahead of the Self Assessment (SA) deadline on 31 January 2025.
Registering and reactivating SA
It takes longer to process tax returns from customers who have not registered for SA prior to submitting their tax return or who did not reactive their SA account.
People who are new to SA must register with HMRC so they can be set up on the system and receive a notice to file. Returning SA customers do not need to register as new, as they already have a Unique Taxpayer Reference (UTR).
If your client registered for SA but did not file a tax return last year, make sure their SA account is reactivated before submitting their tax return. This can be done by the client in their online account, or you can contact us using webchat, by phone, or by using the following print and post forms:
- CWF1 for self-employed clients
- SA1 for clients who are not self-employed
Find out how to register your client or reactivate a Self Assessment account and what forms you should complete.
Quickest way to get your clients tax details
Use the Income Record Viewer to view your client’s:
- PAYE information for the current year plus the 4 previous tax years
- employment records, including time in employment, PAYE reference, taxable benefits and any gap where no record is held by HMRC
- income record
- state and private pension information
- latest tax code for the current tax year including all allowances and deductions
How to get tax returns and repayments right
To help speed up repayment requests it’s essential you:
- register or reactivate your client’s account for SA and wait until they receive their notice to file before submitting their tax return
- check the client’s details are correct and up to date, this includes their bank sort code, account number, UTR, National Insurance number, name and address
- leave 14 days after making a payment before you request a repayment otherwise it will be delayed
- ensure repayment requests for clients who were previously bankrupt are submitted using their post bankruptcy UTR
- notify HMRC of the capacitor if the client died before submitting their tax return and before requesting a repayment
- encourage your clients to receive their repayment electronically — BACs is the quickest and securest method
Marriage allowance sequencing
Tax returns that include Marriage Allowance must be submitted in the correct sequence to avoid delays:
- the person transferring the allowance (transferor) should submit their tax return first if the person receiving the allowance (recipient) is also in SA
- the recipient should leave 72 hours after the transferor has submitted their tax return before submitting theirs
Waiting for a reply
Use the Where’s My Reply tool to check if the due date has passed before using our webchat service or the new option for repayments when you call.
Stopping Self Assessment
If your client needs to stop SA or withdraw their notice to file you should contact HMRC as soon as possible. You can do this using webchat, by calling or writing to us.
Information on how to stop Self Assessment is on GOV.UK which you can pass on to them to action.
If customers do not tell us their circumstances have changed and they no longer need to be in SA, then we’ll continue to write to them, and they may get a penalty if they do not file on time.
Submitting a tax return as an amendment
It’s good practice to submit your client’s tax return as an original, not as amendment to avoid delays.
We receive a high number of tax returns submitted as an amendment using third party software, but we have not received the original tax return.
This results in delays because these tax returns cannot be processed automatically. To make sure tax returns are processed quickly, submit the original tax return as normal and not as an amendment.
Repayments through PAYE
Check with your client if they received a repayment through PAYE and it’s included in their tax return before you submit a repayment claim through SA.
If a repayment has already been made through PAYE, the case is flagged on a worklist which means HMRC will have to check the position manually. This will slow down your client’s claim. There is also a possibility that your client will be paid twice and will then have to repay HMRC.
Prepare online sellers
Tell your clients about the new reporting rules for digital platforms, and the importance of accurately reporting their online sales of goods and services.
By 31 January 2025, online platforms must report to HMRC anyone who sells 30 or more items or earns approximately £1,700 or more in a calendar year.
If your client has sold goods or services on an online platform, such driving a cab or renting a property, and has not paid the correct amount of tax, then work with them to put it right.
Use our online check if you need to do a tax return tool to see if your client needs to complete a tax return.
Find information fast online
Our new agent handbook on GOV.UK is the place to go to help you find guidance. This includes information on registering as an agent, client authorisations, transacting with HMRC and much more.
We’ve added some new tips to help you get the best out of the GOV.UK website and how to find old or archived pages on the National Archives.
The handbook is a new way to present information that mostly already exists on GOV.UK. We want to know what you think of this format and how we could develop it in the future. Give us your views by using the feedback link on the front page of the handbook.
Spotlight 65 — General Data Protection Regulation provision used to reduce tax liability
HMRC is aware of tax agents that target businesses to claim Corporation Tax refunds through incorrect provisions, linked to potential General Data Protection Regulation (GDPR) fines or civil claims.
Spotlight 65 warns about claims featuring GDPR provisions used to incorrectly reduce Corporation Tax liability or claim repayments of tax already paid, or both.
These claims are designed to reduce business profits through the recognition of a provision and a corresponding expense. This leads to businesses paying less Corporation Tax than they should, or claiming Corporation Tax repayments they are not entitled to. Provisions and related expenses should only be recognised in accordance with relevant Generally Accepted Accounting Practice (GAAP).
HMRC’s view is that these and similar claims are not in accordance with the law. HMRC will challenge anyone making such claims who encourages or facilitates businesses to make false claims that reduce tax liability or seek a repayment.
You and your customers should be alert to the details contained in Spotlight 65 as making claims in the way outlined could lead to an error on which tax, interest, and penalties may be due, even if the Research and Development (R&D) element is correct.
Contact HMRC if you have any concerns. If you’re worried about having made an incorrect claim, then HMRC can help.
You can report tax fraud and tax avoidance arrangements, schemes and the person offering you them to HMRC by using our online form to report tax fraud.
Spotlight 66 — Limited Liability Partnerships arrangements used to disguise employment income
Spotlight 66 warns of a tax avoidance scheme called ‘The Partnership Model’ being marketed to avoid payment of tax and National Insurance contributions (NICs). The arrangements are targeted at companies who have employees and are designed to avoid the payment of Corporation Tax and the PAYE deduction of Income Tax and National Insurance contributions from their employees.
This scheme is claimed to work as follows:
An employee of a company enters into an agreement. As a result of this agreement the employee’s employment contract could be changed or terminated in exchange for a compensation payment.
Upon entering the agreement, a Limited Liability Partnership (LLP) is created to pay an employee. This allows the company, through the use of the LLP, to disguise employment income, with the aim to reduce the company’s tax and National Insurance liability.
You and your customers should be alert to the details contained in Spotlight 66 as it is HMRC’s view that this scheme does not work. Scheme users continue to be employees, and payments made to them from the company should be treated as taxable employment income.
If you or one of your customers is worried about having used this scheme, or any other avoidance scheme, you should contact HMRC for helping getting out of the scheme and back on track.
You can report tax fraud and tax avoidance arrangements, schemes and the person offering you them to HMRC by using our online form to report tax fraud.
Where’s My Reply tool updates
We’ve recently added complaints data to Where’s My Reply in response to your feedback. Individual taxpayers and agents can use the tool to find out how long correspondence will take to be processed.
Raising standards in the tax advice market
In the Autumn Budget 2024, the government responded to the recent consultation on raising standards in the tax advice market by making 4 announcements.
Taken together, these are significant steps towards modernising HMRC’s services for tax advisers and making sure advisers meet minimum standards of behaviour.
Modernising HMRC’s tax adviser registration services and mandating registration of tax advisers who interact with HMRC.
The mandatory registration requirement will be introduced from April 2026. HMRC will apply checks to all advisers who register, to ensure they meet a minimum standard. HMRC will publish a technical consultation on the legislation in 2025. Alongside this, the government is investing £36 million to modernise HMRC’s tax adviser registration services.
Consulting on enhanced powers and sanctions for HMRC to act against tax advisers who facilitate taxpayer non-compliance.
The consultation will propose enhanced powers to target the minority of advisers who facilitate their clients paying the wrong amount of tax. The consultation will be published in early 2025 and we look forward to hearing your view. Any legislative changes would be introduced from 2026.
Introducing a new requirement for tax advisers to obtain an Advanced Electronic Signature from their clients if they wish to continue to use the nominations process for certain income tax repayments.
From 6 April 2025, tax advisers who use nominations for the P87, R40 or MATCF print and post forms to claim repayments on behalf of a taxpayer must use an advanced electronic signature service. This new requirement will give greater assurance to HMRC and the taxpayer that the customer has authorised the tax adviser to submit the claim. You can find more details on what you need to do as an adviser in the guidance Receive Income Tax or PAYE repayments on behalf of others.
Considering options to strengthen the broader regulatory framework in the tax advice market.
Taking on board the range of views expressed in the recent consultation, the government will continue to work with stakeholders to consider the case for strengthened regulation of the tax advice market.
We are grateful for the responses we received to the consultation published in March. We will continue to engage with agents and with others on the implementation of all the above measures.
Reminder — tell us your Agent Codes
We’re asking registered agents to tell us which Agent Codes they are using for Self Assessment, VAT and Corporation Tax to help us improve the integrity of the information we hold. This is the first step in an iterative process aimed at improving our service to agents.
You can find a link to the form to complete with the Agent Codes in our reminder email which we sent to agents on 20 November 2024.
We would like to stress that there is no risk of an Agent Code being cancelled in the absence of a response. The only codes we would suspend are those that agents advise are no longer required when they complete the form.
If you’ve received an email from us asking you to complete a form and you are not responsible for managing Agent Codes, pass the email to the appropriate person to complete. We are requesting one response per legal entity even if you have multiple codes or offices.
Individuals who reside both in the UK and other countries — how to avoid errors on SA supplementary pages SA109 boxes 21 and 22
Each year errors are made by customers and their agents when making claims for tax relief under a Double Taxation Agreement (DTA) between the UK and another country. If discovered as part of an HMRC check these errors can result in additional tax becoming due for clients as well as inaccurate penalties and interest.
The tax relief claims are made using Boxes 20, 21 and 22 of the Residence, remittance basis etc Self Assessment (SA109) form. You should also read the SA109 notes to help with filling in the form to make you’re your clients tax returns are correct.
We also recommend reading guidance on how Double Taxation treaties work.
Points to remember when completing the ‘Residence in other countries’ section on page RR 2 of the SA109 supplementary pages:
- if your client wishes to claim relief from UK tax on their UK income and the country they live in has a DTA with the UK, it is important that your client obtains a ‘Certificate of Overseas Residence’ from the Overseas Tax Authorities
- Box 20 should be completed when an individual wants to make a ‘Partial Relief Claim’ and should contain the amount of income to be claimed against under a DTA — we recommend you read Helpsheet HS304 to help you fill in this Box
- Box 21 should be completed when an individual wants to claim tax relief under a DTA between the UK and another country and we recommend reading Helpsheet HS302 to help you fill in this box— it is important that the HS302 Dual Residents claim form is attached to the Self Assessment return together with the ‘Certificate of Overseas Residence’ when submitting this to HMRC
- Box 22 should be completed when an individual wants to claim tax relief because of other provisions within the relevant DTA — you should read Helpsheet HS304 to help you fill in this box— it is important that the HS304 claim form is attached to the Self Assessment return together with the ‘Certificate of Overseas Residence’ when submitting this to HMRC
Further information and guidance can be found on GOV.UK regarding Tax Treaties and the HMRC Double Taxation Relief Manual.
Support for customers who need extra help
We have principles of support for customers who need extra help. These set out our commitment to support customers according to their needs, and underpin the HMRC Charter.
Find out how to get help and what extra support is available.
Contact
Complain to HMRC
You can complain to HMRC.
To make a complaint to HMRC on behalf of your client you must be appointed as their tax adviser.
Where’s my reply for tax agents
Find out when you can expect to get a reply from HMRC to a query or request you have made.
There is also a dedicated service for tax agents to:
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register you as an agent to use HMRC Online Services
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process an application for authority to act on behalf of a client
Manuals
You can check the latest updates to HMRC manuals or subscribe to automatic notification of changes. You can also suggest improvements for pages of our manuals by using the feedback options in the page footer.
Online
You can find online training material and useful resources through the HMRC email updates and webinars for tax agents and advisers page.
HMRC videos on YouTube, online learning modules, and live and pre-recorded webinars are available for tax agents and advisers providing you with free help, learning and support on topical subjects.
Agent forum and engagement
Updates on issues raised on the Agent Forum that are being progressed in the Issues Overview Group.
Missing 2024 to 2025 PAYE code numbers— SA 46134
HMRC are monitoring cases where agents have reported that clients 2024 to 2025 tax codes are not visible in the PAYE notice viewer. To investigate this HMRC need current examples. If you are aware of 2024 to 2025 tax codes not showing in the PAYE notice viewer, use our technical support with HMRC online services to notify us.
We will need you to provide your client’s name and Unique Taxpayer Reference a screen shot of the page and URL. We will not be able to investigate any cases where the tax code was issued over 34 days ago.
2022 to 2023 Returns Delays — SA 47683
Professional Bodies on the Issues Overview Group have raised concerns about delays in processing rejected and amended 2022 to 2023 returns. Around 97 percent of SA returns received were online and the majority were processed automatically. HMRC carries out additional processing work on a small percentage of tax returns. This includes checks, addressing amends made by customers and manually working through returns which are made on paper.
There have been some delays in administrative work relating to Self Assessment returns this year, as customer service advisors were completing this work alongside manning the Self Assessment helpline. HMRC has recently recruited and trained additional customer service advisors who are making a difference.
HMRC has cleared most of the backlog of 2022 to 2023 returns that were rejected and is making strong progress in working through amendments submitted by customers and agents. It aims to clear these by 31 January 2025.
Self Assessment Repayments Failing Automation SA26245
Members of the Issues Overview Group requested that details of common reasons why repayments are inhibited should be published again. These are included in our Self Assessment Manual 113010 — Repayments: repayment work lists: w030 inhibited automatic repayments work list.
Additional Self Assessment tips for agents was published on the Agent Forum on 1 November 2024.
Digital Signatures CGT24134
Following feedback from members of the Issues Overview Group we have now updated HS295 Relief for gifts and similar transactions (2024) confirming that digital signatures can be accepted.
Issues Overview Group Escalated Issues
High priority issues that are escalated by members of the Issues Overview Group (IOG), are moved to the IOG Escalated Issues board for management. When updates on issues are obtained, threads are updated on the Agent Forum and will appear at the top of the list. A webinar on raising potential systemic issues on the Agent Forum, and the operation of the Issues Overview Group is now available.
Agent Account Manager Service
HMRC has a UK wide team of Agent Account Managers (AAMs) to help deal with tax agents and advisers more effectively. AAMs help resolve client-specific issues. They act as an intermediary between agents and HMRC where the normal communication channels have broken down. They act as a single point pre complaints channel to help resolve any ongoing client-specific problems when the usual escalation processes within HMRC have failed. The AAMs mediate with the business area to reach a satisfactory conclusion to issues.
Before using the service, you must first contact the HMRC office you’ve been dealing with or contact HMRC to try and resolve your issue before using the AAM service. Only use the AAM service if you’ve not been able to resolve a client-specific issue through normal HMRC methods. The AAM service does not replace HMRC’s process for formal complaints.
Registering for the Agent Forum
Agents who wish to register for the Agent Forum must agree to the Terms and conditions for using HMRC Community Forums.
Contact Information for professional and representative bodies
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AAT: wt@aat.org.uk
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ACCA Jason Piper: jason.piper@accaglobal.com
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AIA David Potts: workingtogether@aiaworldwide.com
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CIOT Technical: technical@ciot.org.uk
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CIPP Lora Murphy: Lora.Murphy@cipp.org.uk
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CPAA Alison Hale: ahale@cpaa.co.uk
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ICAEW Caroline Miskin: Caroline.miskin@icaew.com
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ICAS Tax Team: tax@icas.com
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ICB Steven Worrall: steven@swaccountants.co.uk
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ICPA: admin@icpa.org.uk
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VATPG Ruth Corkin: Ruth.corkin@hhlp.co.uk