HM Revenue & Customs (HMRC) representatives:
Neil Stenton (PAYE MPPC)
Jen Morgan (PAYE MPPC)
Simon Lidster R (PAYE MPPC);
Margaret Knights (PAYE MPPC) Chair
Sue Higham A (PAYE, SA, NICs Process MPPC)
Carolyn Parmeter (BCU, Carter Programme)
Pam Jones M (IMS Portfolios)
Tim Downes (IMS Portfolios web solutions)
Christine Edge (NTSCI - Complex Personal Tax Teams)
Nigel Plant, P (BCU Carter Programme)
Luca Alessandra (PAYE MPPC) Minutes
External organisations attending:
Institute of Chartered Accountants in England & Wales
British Chamber of Commerce
British Computer Society
Chartered Institute of Taxation
Institute of Payroll Professionals
Electronic Exchange User Group
Payroll Alliance
Business Application Software Developers Association
The consultative forum Chair opened the meeting. The Secretary’s noted apologies received from the Federation of Small Businesses representative and Roger Smith MPPC Programme Director.
Last forum minutes are agreed and action point list updated.
Minutes will be published shortly on the HMRC website.
A great deal of risk mitigation, testing and contingency work has already been done by HMRC and Aspire, in the run up to the April 2008 release of Carter PAYE (Pay As You Earn), which uses a new machine readable validation rules to avoid transcription and coding errors. These rules are already in use in the new Local Test Service. EDI has operated a test in live feature since October 2007 and HMRC has planned a live trial to prove the new service during the first two days of operation. It will also operate a controlled Go Live to prove the interfaces.
In the event of failure, for each April 2008 release component, HMRC has considered the impact on customers and its business units and has plans in place for each scenario to communicate with employers, agents and representative bodies of problems, faults, progress and likely impact to the business. HMRC asked developers to provide a storage facility to their products and other employers can obtain small supply of forms for urgent cases.
Forum External Stakeholders (ES) have asked for prompt system fault messaging and for those messages to be left on website for a longer period of time, so employers are reminded that there was a fault.
Action point 1 - HMRC will pass this request to Online Services.
ES also asked for use of teleconferencing for communicating any problems or just to update members of progress.
HMRC proposed that during the period April to October 2008 any text fields or values that are too large for the COP system to process will be truncated to fit what COP can handle. The business will be alerted to the presence of key fields such as pay, tax and tax code that are too large to be interfaced in full to COP and they will take manual action to ensure that the tax record is correct.
HMRC outlined plans to hold weekly telephone conferencing from mid March, which would address both immediate in year and end of year online filing problems (see also item 7: Concerns over new P45).
Action point 2 – HMRC to provide ES with dial in details.
HMRC presented a preview of an early version of the re-platformed Online Form/Returns Service interface for comments and thanked ES for the advice provided so far. HMRC expect to further improve these screens before its goes live in October 2008 and thanked ES for their feedback and suggestions.
Amongst the advantages of the new interface are the fewer constraints over large volumes of data and a guarantee of better data recognition by the built-in screen readers.
The various online forms appearance is largely unchanged, with unknown NINO (National Insurance Number) still an option; P35 calculation will be moved to next page – where figures are, student loan tax code will be included and there will be a print facility for the P45.
ES suggested a few improvements, such the use of text validation input method instead of existing dropdown boxes; they particularly asked for consistency within the screen input boxes and form titles throughout all forms (throughout Government Departments would also be desirable), to avoid entry and submission mistakes and consequential additional burden. This would also avoid the need of creating separate rules for each form.
ES also asked HMRC to consider the use of the terms in the PAYE Data Dictionary.
HMRC have considered this and most of the data dictionary terms will be used. There are a couple of exceptions, including last name, which will not be changed to surname/family name.
Action point 3 – HMRC will consider ES suggestions and report back via usual channels.
HMRC presented details of the data migration process. There will be a data migration simulation in April to May before migration proper starts in October 2008, during migration, access to the system will be restricted to Aspire and HMRC business only.
This will be an opportunity for HMRC to carry out a match and cleanse data exercise. When the move to PAYE Service takes place, unmatched data will be allocated a temporary reference number and the unmatched query (paper) form will be issued to employers asking for missing or confirmation of unmatched details.
Preparation for this limited data match exercise is on track and migration is expected to go ahead as planned.
Action point 4 – ES asked for reminder to go to employers before migration starts. HMRC will confirm this within the next two weeks.
Release 3 data migration is scheduled for 13/10 to 23/10 in time for Phase 3, Live Implementation, on 27/10. During migration the system will still be accessible to HMRC staff as 'read only', enabling call centres to answer most queries. Employers can continue sending P45s and P46s during migration and controlled Go Live trials. These work items will be stored and dealt by date order once the system is up and running. Some delays will be inevitable but HMRC will prioritise work and manage it as well as it can.
Come 27 October PAYE Service will have a single record for an individual
containing all their employments back to April 2007, coding records and
the end of year clearance position back to 02/03 and have the full functionality
needed to administer PAYE and issue output.
This includes auto-coding of forms P11D and an improved automated EOY
reconciliation process. Staff will be able to access the record from anywhere
in the country and be able to take action on it, depending on the roles
assigned to them.
EOY reconciliation will be automated and be based on the P14s received for each employment. HMRC will post the P14 data against the employment and reconcile the case when all expected P14s have been received. Where HMRC get an unexpected P14 (there is no employment on the record), it will create that employment, post the data and incorporate it in the reconciliation/re-reconciliation. The EOY reconciliation process will also incorporate P11D data and P810 (Targeted Review form) information.
HMRC will be testing the new system for six week in Portsmouth and Sunderland offices and in Newcastle the Live System will be tested between June and October.
The new PAYE Service will bring big changes for HMRC staff, as the new
automated system, not the operator, will decide which case needs attention
next.
As a precautionary measure HMRC will keep the current PAYE system 'COP'
running for the whole of 08/09 Tax Year.
New P46: this from has been approved and will be available for printing. There is a Welsh version and help cards will be available in 46 languages.
New P46(PEN) to be introduced in April 2009: feedback is still coming in.
New P46ExPat: see item 9 below.
New plain paper P45: still being approved and forum ES and HMRC reviewed this form and current design specifications published on our website.
ES are concerned that, as both black and white and colour printing are allowed, recipients could assume that a black and white copy is a fake adding burden to employers and HMRC dealing with such queries, so adequate publicity will be needed.
ES think that better guidance is required over the timing of issue of P45 employees, as wrong timing could facilitate fraudulent activity and asked HMRC to revise current guidance. ES will need reassurance that employers will not foot the bill of any frauds committed by individuals.
HMRC will consult ES over this issue further through planned teleconferences from March 2008 (see AP2).
ES are also concerned that moving from A5 to A4 P45 paper format could add to postage costs.
Action point 5 - HMRC to revise current guidance and ES to send any further feedback via the usual channels.HMRC announced that it has been decided to issue separate guidance for Employers providing pension schemes to their employees will be published on the Internet as soon as possible.
Action point 6 – HMRC expect to circulate a draft for comments.
HMRC presented a proposal for a new P46(Expat) form for use within the PAYE Service from April 2009. The new form is designed to provide a better service to individuals not domiciled in the UK, who are seconded as employees to work wholly or partly in the UK by a non-UK resident employer using a UK host employer or their UK branch for payroll purposes, for a period of time usually between 60 days and three years. Receipt of this form will create a unique work item and ensure it is dealt by HMRC in the appropriate office. Pending consultation and approval, this form will replace the existing informed P86 arrangements from April 2009.
HMRC issued a working copy of this new form to all attendees and asked ES to provide any feedback to forum secretary.
ES again stressed of the importance of having consistency of box headings, input boxes and form names purpose across all new stationary, also ensuring that it is clearly stated what a particular form is for and perhaps setting up a set of questions before download begins to prevent mistakes.
ES also suggested for a tax code box to be added to the student loans window and said that it would be helpful if individuals could also submit P46 Expat.
HMRC replied that this could be cause confusion and facilitate fraud.
ES asked for proper consultation over the design of P46 form and instructions to employers.
At April 2009 there will be a small final release that allows HMRC to issue forms P810 in bulk. These forms are issued to individuals who have investment income or other non-PAYE income but who are not in SA (Self Assessment). HMRC carries out an annual issue of these forms and the 2008 bulk issue will be done from COP in April 2008.
Between April and October 2008 HMRC will log receipt of these forms and make any code amendments necessary. Between October and April 2009 HMRC will log receipt of remaining forms on the PAYE Service and have the functionality to issue forms manually. The P810 data will be entered into the system and the code number will automatically be amended, and the data automatically included in the EOY reconciliation.
New warning and penalty letters for sending paper submission are being drafted and will be circulated for comments as soon as possible.
HMRC communications are being stepped up to ensure both internal and external businesses will be ready for roll out and online filing changes and in order that customers understand the changes within HMRC.
More information for the Employers will be published on website in early February, March and throughout the months leading roll out with a steady flow of information available as LID approaches.
An online filing video will feature in the Budget edition of Employer CD-ROM.
HMRC are also looking at feasibility of countrywide radio broadcasts announcing the changes.
Please see the MPCC Communications Events plan for details.
HMRC asked the forum to comment on the plan and on effectiveness of video,
preview of which will be circulated in around a month time.
1) Business by telephone and contact centres Statement Of Practice (SOP).
The current SOP which dates back to 2005 allows Contact Centre staff to accept new employment details and works numbers over the phone from individual.
The Programme would be keen to see this changed, so that only employment information coming from employers is to be recorded and they are working with appropriate bodies to implement these changes.
2) HMRC will be unable to validate P45 forms which have a leaving date of April 2008 but are submitted in March 2008.
Next meeting
The forum agreed to hold next meeting on 30 April 2008 as planned. All dates of future consultations in 2008 can be found on our website. However HMRC offered to hold teleconferences with any ES wishing to join in starting from early March 2008, see action point 2.
Forum ended at 14.30.
Luca Alessandra
Recurrent - ES to forward any questions/topics around the new system for inclusion at future meetings. Ongoing - All.
Recurrent - Secretary to update external reps details. Ongoing
-Ongoing
Next review due in June 2008.
