PAYROLL INSIGHT
us all with a warm Borders’ welcome that played a valuable role in gathering more insight into this latest proposal. Our consultation response It is fair to say that the CIPP is disappointed that other options weren’t previously considered in a public consultation, and we are concerned at the proposed direction of travel as it relates to government’s use of the real time information (RTI) system. It is also fair to say that the proposals on accounting for the de minimis state aid amounts were met with wide-spread objections. Thank you to all members who were generous enough to share their time to feed into our response. In our written response (which can be read in full here: cipp.org.uk/my-cipp/ policy-hub ) to the technical consultation we made several recommendations, and reiterated that we are of the belief that the draft Employment Allowance (Excluded Persons) Regulations should not be passed in their current form. This is because they place on employers’ payroll processes unacceptable levels of administrative burden – not least because the data required within the declaration is not available to the payroll function and so will require significant manual intervention. We recommended that:
● ● As with any new policy or policy adaptation it is vital that a good communications plan which makes use of all communication avenues open to HMRC is used, and to an appropriate timescale. Such resources include direct communications to inform all employers about the policy change (i.e. hard-copy letters planned for later in the tax year – February/March). Whilst electronic communications are not ideal, if also used they will ensure that all who are involved in submitting the employer payment summary (EPS) will have been made aware; this is a high-level communication, but it is important to ensure it arrives at the correct place. ● ● Guidance should be updated on GOV. UK pages at a basic level as well as a more-advanced level, that considers more complex or unusual circumstances and the needs of agent and service providers. Please continue in this vein with a clear explanation of: ❍ ❍ De minimis state aid – the sectors affected as well as the principle, which must include good examples of what employers need to be aware of i.e. how they might receive such aid. ❍ ❍ The impact of the ‘less than £100,000’ on class 1 secondary NICs liabilities – how is this calculated and what exclusions are there from this amount?
We understand that secondary NICs arising from ‘deemed’ payments are to be excluded – is this for all employers or simply personal service companies/ intermediary employers that directly employ the contractor? This needs to be made clear. ❍ ❍ Can the £3,000 be offset against all class 1 secondary NICs or are there any exclusions? Again, this needs to be made very clear, not only to software developers but also to employers, agents and payroll providers. ● ● Use of webinars (detailed and technical ‘talking points’ for agents) and employer webcasts. ● ● Use of stakeholder engagement to cascade the message across all sectors (particularly those that have limited state aid ceilings) and professions. ● ● A brief summary in the Employer Bulletin and Agent Update – which ideally will have working links to updated and accurate pages on GOV.UK – is not enough. ● ● Frequently-asked-questions sheets have been found to be useful in the past and we would be happy to supply suitable questions – we have many. We are aware of the limitations that Government Digital Services (GDS) place on the format of information held on GOV. UK and we would be happy, together with other stakeholders, to cascade such information. We continue to be frustrated at the limitations that GDS place on information uploaded to GOV.UK. Our work is not simple, and neither will it become so with this latest policy change. So, the guidance
...guidance should equally not be simple – it should comprehensively provide for all needs and be provided in all formats
Employment allowance EPS data items from 2020/21
166 Employment allowance indicator
rule changed
199 Employer is in the agriculture sector
added
200 Employer is in the fisheries and aquaculture sector
added
201 Employer is in the road transport sector
added
Employer is in the industrial sector (Complete this item if the employer is involved in economic activity, and is not within the agriculture, fisheries and aquaculture or road transport sectors) State aid rules do not apply to employer Complete this item if the employer is not undertaking any economic activity (e.g. charities, community amateur sports clubs, employing someone to provide personal care)
202
added
203
added
204 Enter 0.00
added added
205 ‘euros’
| Professional in Payroll, Pensions and Reward | November 2019 | Issue 55 18
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