General - other
- Agent authorisation
- Discussing your clients' affairs with HMRC
- Enquiry window - updated August 2009
- Practitioner change of details
- Requirement for client UTR
Agent Authorisation
Form 64-8 (Authorising your agent)
While there are some exceptions where the 64-8 needs to be sent to other HM Revenue & Customs (HMRC) offices, the majority should be sent directly to the Central Agent Authorisation Team (CAAT) at Newcastle:
HM Revenue & Customs
CAA Team
Longbenton
Newcastle upon Tyne
NE98 1ZZ
More information about when you need to send the 64-8 to another office can be found at:
Where to send 64-8s.A substantial increase in the number of forms 64-8 received by CAAT in the past couple of years led to authorisations being delayed and HMRC are sorry for any inconvenience that this may have caused. Nearly 90 additional staff were trained and deployed to address the backlog of forms that had built up and HMRC are now in a position where it is pleased to report that in the majority of applications CAAT are able to process forms 64-8 within a few days of receipt.
HMRC have begun a review of the 64-8 process, and continue to work closely with agents to identify ways of streamlining and improving the service provided.
There are a number of straightforward things that agents can do to get the best out of the authorisation process:
- Do not send forms 64-8 to local offices unless it is specified as one of the exceptions that CAAT cannot deal with. Currently more than 40 per cent of the forms that CAAT receive come via local HMRC offices and this can invariably result in significant delays.
- Use the latest version of 64-8 that can be downloaded or completed on-screen
and printed. Only tick the boxes that are necessary as this will help CAAT
process forms more quickly.
form 64-8 (PDF 72K) - Ensure agent codes, reference numbers, National Insurance numbers and Unique Taxpayer Reference (UTR) are recorded on all forms submitted.
- Standardise handwriting on all forms to ensure that they are completed in block capitals.
- Use online process instead of the paper 64-8 route.
- Ensure forms are completed correctly.
- Inform HMRC in advance when bulk processing is required.
- Some agents choose to submit duplicate 64-8s for all of their clients on an annual basis to ensure their authorisations are up to date. This only adds to the CAAT workload and will delay the processing of new authorisations. HMRC would like to recommend the online option that is mentioned above to provide agents with direct and speedy control in relation to the maintenance of their client lists.
Agent Authorisation for PAYE and CIS
For PAYE (Pay As You Earn) Online form FBI2 (Authorising your Agent to use PAYE/CIS Online Services to receive information over the internet) is required in addition to a 64-8. From 6 April 2007 the PAYE Online service was changed to support both PAYE and Construction Industry Scheme (CIS) Online business. This was not because there is any direct connection between PAYE and CIS, but simply because there was an existing proven business process that new CIS could be built on.
Agents who were already registered and enrolled for the PAYE Online Service before 6 April 2007 were automatically migrated to the new PAYE/CIS Online Service for Agents. This meant that they did not need to register and enrol again.
However, any client authorisations in place for PAYE were specific to PAYE and could not be automatically carried over to CIS. This was because the original 64-8, FBI2 or online agent authorisation for PAYE would not have contained any client authorisation to act on CIS business. Use of the new CIS service for verifications or access to HMRC's free filing application will allow access to subcontractor information. This cannot be given out online without a formal authorisation being in place.
Agent authorisation for partnerships
It is necessary for a 64-8 authority to be made in respect of the partnership as well as in respect of the individual partners, even if the same agent is to be authorised.
64-8 new client for multiple services
A single form 64-8 can be used to authorise an agent to represent a client for as many of the following services as are appropriate:
- Individual/Partnership/Trust Tax Affairs (including National Insurance)
- Tax Credits
- Corporation Tax
- Employer PAYE scheme
- VAT
Agents need to be aware that the paper 64-8 does not authorise them to file electronically on behalf of clients for VAT. Online filing is not available for any tax credits forms.
Guidance on where to send the completed form can be found in section 5 of the form itself.
Online agent authorisation
Currently only a minority of agent authorisations is made via HMRC's online authorisation process and HMRC would like to encourage agents to consider the benefits that they could gain by using this. The process allows agents to set up authorisations for the majority of their clients and removes the need to submit paper 64-8s or FBI2s.
Once authorisation has been requested and accepted an authorisation code will be sent to your client within seven days. The letter will be sent to an address known for the relevant service (Self Assessment, PAYE etc). It will clearly state which service it relates to and the code will be prefixed with two identifying letters for example SA for Self Assessment, CT for Corporation Tax and PE for PAYE. In the case of PAYE, the code is sent to the company address and marked for the Company Secretary, but for Self Assessment the address to which the letter is sent may be the client's home address if this is the one held. The authorisation code is issued in a plain white envelope marked Business post on the front and with the Government Gateway stamp on the back. Any delays should be reported to the Online Services Helpdesk Tel 0845 605 5999.
When using the online authorisation process you need to apply separately for each service, but you may request authorisation for up to 30 clients at one time.
Client lists
If you file online for a client using the File only service and subsequently submit a form 64-8 or online authorisation application, your client will then appear on your authorised client list. HMRC advise that you should nonetheless retain your client's name on your unauthorised client list, as this will enable you to retain access to forms submitted before you became the authorised agent.
Where there are known problems with client lists you will be able to find information about these on the Service Availability pages of the website, under Service Issues. If you cannot find any mention of the problem you are experiencing you should contact the Online Services Helpdesk (Tel 0845 605 5999).
Change of client details
You can change certain client details using the online system. For further information please refer to the Frequently Asked Questions (FAQs). Note that if your client pays more than one type of tax – for example, a company liable for PAYE, VAT and Corporation Tax - you need to make the changes separately for each of them. This is because the information is not automatically shared across all our corporate systems.
If your client is a limited company there are special procedures for changes to the registered name/address of the company. You can find more information about this in the item on Corporation Tax Online: Change of address, and further guidance is available here:
Online Service FAQs
Change of name and address
for limited companies
Discussing your clients' affairs with HMRC
Agents sometimes find that HMRC staff are unable to discuss the affairs of a taxpayer who is on the agent's online client list, and who has previously completed a 64-8 authority for that agent. The agent authorisation arrangement is in place to safeguard you and your clients. HMRC staff are only permitted to discuss your clients' affairs with you if they can clearly see that a 64-8 is in place for you, and for the particular service you wish to discuss. Several factors may prevent this, including:
- individual members of staff have access only to certain computer systems - the information from these systems does not automatically flow across to all others
- agent authorities of long-standing may be based on previous editions of the 64-8, and your client may not have specifically authorised you for every service
- agent authorities of long-standing have, in a few cases, been lost from the systems
A particular example is the Newly Self-Employed Helpline, whose staff refer to the NIRS computer system to check the agent authority - if you are not authorised to represent your client for National Insurance matters they will not be able to discuss your client with you.
Unfortunately in most cases the only course of action possible if there is no record of the authority is to obtain a new 64-8 from your client. It is appreciated that this can be inconvenient but HMRC must take great care to ensure that it does not discuss personal matters with anyone other than those who are specifically authorised representatives.
Enquiry windows - updated August 2009
Lord Carter recommended that HMRC should link the enquiry window for Self Assessment and Corporation Tax to the date of submission.
Corporation Tax
The time limit for the taking up of an enquiry has been amended by Finance Act 2007 for accounting periods (APs) ending after 31 March 2008.
- for singleton companies or companies in small groups where a return is received on or before the filing date, the time limit is 12 months from the date of receipt of the return
- for companies in a group that is not ‘small’ where a return is received on or before the filing date, the previously existing rule still applies and the time limit is 12 months from the filing date
- for all companies where a return is received after the filing date, the
previously existing rule still applies and the enquiry window closes on
31 January, 30 April, 31 July or 31 October next following the first anniversary
of the day on which the return is delivered
The definition of a group that is ‘small’ is in S383 Part 15, Chapter 1 of the Companies Act 2006.
No change has been made to the current rules in the case of amended returns. Submitting an amendment will extend the window for opening an enquiry. HMRC can open an enquiry up until the anniversary of the quarter date following the date the amendment is received. If the time limit for enquiry into the original return has expired any enquiry is restricted to those entries which have been amended.
As before no specific notification of the enquiry window will be given. All companies receive, and will continue to receive, a paper acknowledgement of their Company Tax Return and Self Assessment shortly after the return has been received by HMRC. For online filed returns when the electronic package reaches HMRC a message notifying its arrival is issued.
The Frequently Asked Question (FAQ) gives further information about the procedures followed.
What happens once my return has been sent in?
Self Assessment
The one year period will run from the date of receipt of the return, provided it is received on time. No receipts are issued for paper returns but receipt of online returns is acknowledged by email. Again, as now, no specific notification of the enquiry window will be given for either online or paper returns.
No change has been made to the current rules in the case of amended returns. There are two separate enquiry windows, one for the return itself and one for the amendment. For 2007-08 the amendment window runs to 31 January 2010.
You can find out more about Self Assessment by reading our:
Practitioner change of details
This table has been produced to help you notify HMRC successfully when you change your address, or when you merge your practice with another. Because the computer systems have been developed separately HMRC regret it is not yet able to offer agents a 'one-stop' arrangement for change of details.
Service |
Change of Address |
New client authorisation required? |
Practice merger |
New client authorisation required? |
|---|---|---|---|---|
Self Assessment |
|
No
No |
|
No
No |
Corporation Tax |
|
No
No
No |
|
No
No
|
PAYE |
|
No |
|
No |
CIS |
|
No |
and |
Yes
|
VAT |
|
No
|
and |
Yes
|
Pensions Schemes |
|
No |
|
Yes
|
National Insurance |
|
No |
|
Yes |
Tax Credits |
|
Yes |
|
Yes |
Requirement for client Unique Taxpayer Reference (UTR)
To file a Self Assessment return online, or to use the online agent authorisation service, you must have the client's UTR. This is to protect the client/agent relationship and the client's data. The UTR must be applied for by the client.
HMRC know that some of your clients have experienced delays in the processing of their applications and apologise for the inconvenience this has caused. Recently HMRC have been conducting a review of CWF1 and other UTR processes and are seeking to improve its service.
Currently to obtain a UTR for a self-employed person you should phone the Self-Employed Helpline on 0845 91 54 655.
Alternatively your clients can complete an online CWF1. Paper forms CWF1 should normally be sent to the CAAT at Longbenton.
