PAYE46050 - employer returns: employer return post capture: form P227 and regulation 72

'Important' and 'Unimportant' errors

You will use different methods to resolve error(s) made by an employer, depending upon the 'importance' of the error.

An employer's error may be considered as 'unimportant' if it is due to lack of attention rather than incorrect application of instructions or procedures. Size does not itself make an error 'important'.

The Debt Management Office must always get form P227 and a report where the employer has

  • Underdeducted tax of more than £100 from any single employee
  • Failed to add back refunds not made to employees because of a trade dispute and there are 'important errors'
  • Failed to operate PAYE satisfactorily

Regulation 72

Detailed guidance on the Debt Management Office's involvement in Regulation 72 provisions can be found in the PAYE Instructions (Collection) Manual from PA6.100

An employer can be held responsible only for the tax that the PAYE Regulations required them to deduct. If an under deduction arises through no fault of the employer, then Regulation 72 does not apply.

Only the Debt Management Manager can relieve an employer of his responsibility for payment of tax under-deducted from an employee's earnings by means of a 'formal direction' on form P106 under Regulation 72.

The Debt Management Office has three possible courses of action

  • To make a formal direction under Regulation72
  • To collect all of the under deduction
  • To collect some of the under deduction and make a direction under Regulation 72 for the balance

They will also collect any refunds due to employees after a trade dispute.

Any queries regarding a Regulation 72 direction must be referred to the Debt Management Office.

Regulation 80(3)

Regulation 80(3) precludes recovery under Regulation 72 once a determination is made.

If you are required to deal with such a determination follow the Action Guide 'Regulation 80 Determinations' PAYE46091.