Policy News Journal - 2012-13

Whilst we understand that this does not give very much time for you to complete this survey , we hope that members will appreciate the opportunity to have more input into shaping HMRC’s RTI penalty regime.

RTI P46 CAUSING CONFUSION

31 October 2012

Many members have contacted the CIPP Policy team this week asking about the new P46 claiming to be the RTI P46. Although the title in the link ( http://www.hmrc.gov.uk/forms/rti46.pdf ) shows RTI 46, it is in fact a starter form check list. This is something the representative bodies including the CIPP asked HMRC to provide to help businesses, in particular the small employer, especially as the starter process under RTI requires this information even if the employee provides a form P45. Many employers will include this information in their company recruitment starter packs, along with terms and conditions etc. so it provides a useful check list for members.

We would welcome your feedback on this form so please do use the comment box below to share your thoughts.

CIPP MEMBERS PROVIDE HMRC WITH ADDITIONAL INFORMATION FOR REAL TIME INFORMATION PENALTY MODEL

6 November 2012

Last month the CIPP Policy asked members for their help in providing HMRC with extra information about further issues they were exploring with RTI penalties.

The Policy team would like to thank all those members who responded to our survey. Below is an excerpt from the response that has been submitted to HMRC which gives a summary of the results. The full set of responses is also available to view in the PDF document below. Background Following the recent HMRC consultation on securing compliance with RTI, HMRC advised at the RTI Customer User Group meeting held on 19 October, that there were further questions which had arisen as a result of the consultation exercise. The CIPP volunteered to put these questions to its members allowing HMRC to gain a wider range of responses. Given HMRC’s tight deadline, members were given two weeks to respond to an online survey. Thirty six responses were provided in total. Summary Overall respondents considered the initial penalty amounts to be fair for smaller employers but not proportionate for larger employers, which many felt should be significantly higher than suggested by HMRC. Almost all respondents were in favour of escalating penalties for continued default. Although views ranged on the timing and amount of the additional penalty, the majority favoured escalating penalties commencing after three months. Most respondents agreed with the concept of an easement for new employers, with the majority favouring that penalties begin after a certain period of time. As expected, the timing of this varied enormously, however a period of 3 months was most commonly specified. HMRC were interested in employer views regarding an additional penalty for late submission of the final FPS for the year. Respondents were relatively evenly split, with some feeling that it would attract a penalty anyway if it were filed late so there would be no extra incentive, but others felt that filing after 19 May, which is a familiar deadline in payroll, should attract an additional penalty.

CIPP Policy News Journal

12/04/2013, Page 197 of 362

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