never knowingly bettered...5 a word on software much of hmrc’s development for agents is based on...
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NEVER KNOWINGLY BETTERED
For Quality | For Security | For Service & Reliability
Practice Compliance Outsourcing Final accounts production • Personal tax returns
Corporation tax returns • Cloud Bookkeeping
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The secure solution that keeps you connected to your clients
Making Tax Digital – what
now?
Rebecca Benneyworth MBE BSc FCA
2020 Webinars
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This will happen!
Bear in mind that the driver for much of
this is the promised Tax Gap savings
Whether you believe them or not, HMRC
/ HMT / HMG do!
So you should view the exemption long
term as £10,000 or the personal
allowance
Even if we get an interim solution
Modernisation of HMRC computer
systems A very important part of this
A very expensive exercise
BUT offers gains for taxpayers and agents
(ultimately)
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A word on software
Much of HMRC’s development for agents
is based on API’s
These will pick up data from HMRC’s
back end and display it in your software
But only if your software provider builds
it
◦ Some will not
◦ Some will take a long time
Think about this as you go forward
Overview of consultations
Six consultations in all
A – Bringing business tax into the digital age
B - Simplifying tax for unincorporated
businesses
C – Simplified cash basis for unincorporated
property businesses
D – Voluntary pay as you go
E - Tax administration
F – Transforming the tax system through better
use of information
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What does a digital tax system mean?
For the taxpayer ◦ The end of the tax return
◦ The ability to pay tax based on your business activity during the year
◦ The ability to upload or update your tax account in real time
◦ All of your tax information in one place
For the tax authority ◦ The end of the tax return
◦ Smoother processing of data by removing peaks
◦ Better interaction with taxpayers
◦ Ability to support taxpayers to “get it right first time”
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The digital tax account
For businesses this means
◦ All of your tax information and interactions are in one place
◦ No separate notifications of change of address or other details
◦ Easy payment, time to pay and other options
◦ Less direct contact with HMRC
◦ The ability to appoint an agent for the services you choose
For HMRC this means
◦ Merging many back end systems to make a seamless front end
◦ The “Customer Golden Record” – all of the information about a business in one place
◦ Therefore the ability to target information and support much more directly
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A – Making business tax digital
The key elements
◦ Businesses REQUIRED to keep digital
records
◦ Businesses to update HMRC quarterly
with summary data
◦ The annual taxable profit calculation
◦ Commencement for income tax from
April 2018 (based on accounting period)
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Under £10,000 turnover (More?) or gross
rents will be exempt from the
requirement to keep digital records and
update quarterly
The next rank of businesses will have an
extra year to prepare
◦ Don’t know which businesses or how long
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Small businesses
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Digital record keeping
Use any internet enabled device – most apps will
be cloud based
Record income and expenditure as near to real
time as possible
◦ The option of free software for the smallest
businesses
Other support from HMRC with transitional
and ongoing costs
◦ What form might this take?
Recent announcement – spreadsheets will
qualify if used with MTD software
◦ Think about your attitude to this 15
Exemptions
Under £10,000 turnover / gross rents (NB added
together) – whether a secondary source of income or not
Charities, CASC’s
Exemption for those who “cannot engage digitally”
◦ Currently defined for VAT – 2 categories
◦ A person who is a practising member of a religious society or
order whose beliefs are incompatible with the use of electronic
communications
◦ Persons for whom online filing is not reasonably practicable for
reasons of disability, age, remoteness of location or any other
reason.
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Quarterly Updating
This is not (and never has been) four returns a year
Rests entirely on digital record keeping
◦ This should be almost automatic once the transactions have been captured
◦ One month to submit, no more than 3 months after the last
◦ More frequent updates possible
Summary level data only – but more detail in transactions
Option to capture accruals, stock, tax adjustments if desired
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Review or check before submitting?
◦ Or pick this up when finalising profits for the
year?
Will produce a tax calculation and
business can pay early if they want to
Three line account for businesses below
VAT threshold
No penalties for inaccuracy
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Quarterly Updating
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Finalising the year
Proposed that this is a stand alone process but
for some could be done with Q4 update
10 months after the end of the accounting
period
◦ Extended as a result of consultation responses
Accounting simplification (see later) might make
this easier
◦ Consider the cash basis – but with caveats (see later)
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Prompts and nudges
Support for the taxpayer as and when he
completes his accounting records
◦ And when the quarterly update is being put together
by the software
Identifying common errors and highlighting
where the data “looks wrong”
Embedded within accounting software apps
Intended to increase accuracy as early as
possible
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Start thinking about affected clients
Certain for turnover in excess of VAT
threshold
And start date will not move
◦ First accounting period starting after 5 April
2018
Shift to 31 March accounting dates?
◦ Delays start by 12 months
◦ Release overlap profits
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Your next steps
Software for accounting
You will need a minimum of the SA
categories
Similar for landlords – categories from
Land and Property pages
Even if filing three line account
Design standard template?
Flex for individual clients?
Cloud based?
◦ Looks like the way to go
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Photo capture software
Frequently inaccurate
Can use scanner based software
Need “ideal conditions”
◦ Light, level, A4
But there is a place for it
Digitises the content and posts to
accounts
Bank streaming software
“Screen scraper” approach
◦ May have compromised bank security
◦ Banks not keen
Direct feed – Bankstream as was
◦ Others now have this too
◦ Lloyds bank unable to support
◦ Most banks charge a monthly fee
◦ Santander does not
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What is your role?
Increase bookkeeping support
Staffing?
Pricing?
The Australian example!
No more clients turning up in January
with their accounting records!
The overlap!!
April 2018
April 2019
April 2020
SA returns 2017-18
Prepare clients for change
Quarterly filing for early starts Quarterly filing for all
VAT returns filed in MTD
First year end updates
SA returns 2018-19
Companies join MTD
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B - Simplification
4 Elements of the proposals
◦ Increase turnover threshold for the cash basis
◦ Reforming basis periods
◦ Simpler reporting outside the cash basis
◦ Reforming the capital / revenue divide within the cash
basis
Some merit in these proposals
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Responses
Cash basis limit increased to £150,000
Exit limit £300,000
Changes from April 2017
Do you want to move clients to cash
basis?
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The cash basis – issues to consider
Much simpler and a more natural fit with MTD
BUT
◦ Ability to tailor capital allowance claims to retain benefit
of personal allowance is lost
◦ Interest and related costs capped at £500
◦ No loss relief other than carry forward
Delay in paying tax for many businesses – but this
is temporary
◦ Will it reverse when the business is paying higher rates
of tax?
◦ Incorporation / cessation / exceed upper threshold?
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Basis periods reform
Policy aim – to eliminate overlap periods and allow
much more flexibility
Suggestion provided but open to any other ideas
◦ Choose any accounting periods you desire, with a
maximum length of 12 months (and consecutive – no gaps!)
◦ Tax for a year is based on the accounting periods ending in
that year
◦ But business can end accounting periods on any date they
choose – there is no fixed “year end”
More thought to be given
Proposal did not cover partnerships
Await further consultation
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Simpler reporting outside cash basis
Reducing the GAAP adjustments required – to
make reporting easier but outwith the cash basis
◦ No closing stock adjustment – care needed as this may
distort profits
◦ Contracts with length up to one year – no need to
recognise until billed
◦ No bad debt provisions (just write off the debt when
irrecoverable)
◦ No adjustment for accruals / prepayments if they relate
to a maximum of one year
More thought and further consultation
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The capital / revenue divide in the
cash basis
General disallowance of capital expenditure to be replaced
by a more specific disallowance of expenditure on the
provision, improvement or disposal of:
◦ Real property (including fixtures within) (new fixtures would be
allowed)
◦ Intangibles unless there is a definite fixed life of 20 years or less
◦ Another business including goodwill
◦ Financial instruments
◦ Any other asset which does not have an effective limited life or
cannot reasonably be expected to reduce in value over the time
it is used
Welcomed by responses – this will go ahead
More clarity
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C – cash basis for property businesses
Gross rents limit to be set at cash accounting limit for traders
◦ Default is cash basis
◦ Opt for accruals basis
No restriction on interest costs other than announced previously – compare to the cash basis for traders
Tenant deposits not regarded as income until end of the lease
Cash basis is when rent is paid to agent
◦ Not when agent passes rent over
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D – Voluntary pay as you go
Offered as an option
No current plans to change payment dates
Some businesses have requested this
Voluntary payments at a time chosen by the
taxpayer
◦ In line with quarterly updates?
◦ Regularly by direct debit?
◦ Variable as and when?
Design principle – simple, flexible, voluntary
HMRC providing good clear information on
likely liabilities
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Voluntary payment Suggested screen layout
Period 1 Estimated tax and NIC due for the year 31.3.xz £1,200 Make Vol Payment
20xx/xy Second Payment on account becoming due 31 July £1,500 Make Payment
This amount must be paid by the due date, or an application made to reduce payments on account. This liability relates to your profits for the year ended 31 March 19xy.
20xy/xz tax year
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Estimated tax and NIC due for the year £2,200 Make Vol Payment
Period 2
Payment made so far (Credits) £1,200
20xy/xz tax year
Estimated tax and NIC due for the year £3,200 Make Vol Payment
Payment made so far (Credits) £2,200
Period 3
20xx/xy Final payment becoming due on 31 January £ 250 Make Payment Apply credits
20xy/xz First payment on account becoming due on 31 January £1,625
The Payments on account made in January 20xy £1,500 and July 20xy £1,500 have been set against the total amount due of £3,250. If you prefer, you can allocate some of your voluntary payments against the amount due. Choose “Apply credits”.
The voluntary payments you have already made cover this amount. There is no need to pay anything further to cover this liability.
20xy/xz tax year
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Payment made so far (Credits) £2,950
Period 4 Estimated tax and NIC due for the year £3,950 Make Vol Payment
The payments you have made so far this year (shown as credits) have been reduced to cover the final payment for the 20xx/xy year of £250.
20xy/xz tax year
Estimated tax and NIC liability for the year - awaiting year end declaration £3,950
Make Vol Payment
20xy/xz Second Payment on account becoming due 31 July £1,625
20xy/xz tax year
Payment made so far (Credits) £3,950
There is no need for you to make a payment on account in July, as your voluntary payments cover the liability due.
20xz/ya tax year
Period 1 Estimated tax and NIC liability for the year ended 31.3.ya £1,000
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Make Vol Payment
20xy/xz tax year
20xz/ya tax year
Period 2 Estimated tax and NIC liability for the year £1,900
Payment made so far (Credits) £1,000
Estimated tax and NIC liability for the year - awaiting year end declaration £3,950 Payment made so far (Credits) £3,950
Make Vol Payment
20xy/xz tax year
Payment made so far (Credits) £3,950
20xz/ya tax year
Period 3 Estimated tax and NIC liability for the year £2,800
Payment made so far (Credits) £1,900
Year end update. Final liability for the year £4,060
Final payment for the 20xy/xz tax year due 31 January £ 110 Make Payment
20xz/ya First payment on account becoming due on 31 January £2,030 Your current submissions indicate that the profit for 20xz/ya will be lower than for 20xy/xz. Click “Reduce” to set payments on account to the amounts shown by your quarterly submissions. Alternatively, to cover both this and the final amount show above you need to pay £ 240
Apply credits
Make Payment
Reduce
If you prefer not to pay this amount, you can use the voluntary payments you have already made. Choose “Apply credits”.
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Payment made so far (Credits) £2,690
Period 4 Estimated tax and NIC due for the year £3,420 Make Vol Payment
The payments you have made so far this year (shown as credits) have been reduced to cover the final payment for the 20xy/za year of £110.
20xz/ya tax year
Make Vol Payment
20xz/ya tax year
Payment made so far (Credits) £3,420
There is no need for you to make a payment on account in July, as your voluntary payments cover the liability due.
20ya/yb tax year
Period 1 Estimated tax and NIC liability for the year ended 31.3.ya £1,400
Estimated tax and NIC liability for the year - awaiting year end declaration £3,420
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Make Vol Payment
20xz/ya tax year
20ya/yb tax year
Period 2 Estimated tax and NIC liability for the year £2,400
Payment made so far (Credits) £1,400
Estimated tax and NIC liability for the year - awaiting year end declaration £3,420 Payment made so far (Credits) £3,420
Make Vol Payment
20xz/ya tax year
Payment made so far (Credits) £3,420
20ya/yb tax year
Period 3 Estimated tax and NIC liability for the year £2,800
Payment made so far (Credits) £1,900
Year end update. Final liability for the year £3,180
You have overpaid. Would you like this amount repaid or £ 240 it can be carried forward against next year?
Make Repayment
20ya/yb First payment on account becoming due on 31 January £1,590
Your payments so far are sufficient to cover this amount, so you have nothing to pay.
Carry forward
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E – Tax administration
No new compliance powers to look at quarterly
updating
◦ Tailor existing compliance powers to mesh with the
new regime but not regular updates
◦ Retain all existing taxpayer safeguards
Late submission penalty – move to a points
based system
◦ No immediate penalty
◦ Penalty imposed once a certain level of points accrued
◦ Some recognition of compliance history
Most of this will go ahead
◦ Some design aspects to solve 47
More on penalties
Inaccuracy penalty as now
◦ Triggered after “End of year declaration”, not on quarterly
updates
Determinations etc. unchanged except for wording to
meet the new system
Late payment penalty converted to penalty interest
◦ Applies when the debt is unpaid after 14 days and customer has
not negotiated time to pay or stuck to an agreement
◦ Might escalate at each penalty point
◦ In addition to late payment interest under current rules
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F – Better use of information
Better and more effective use of third party information to
keep the tax collected closer to the correct liability
Taxpayers update their digital tax account regularly –
nearer to real time
From April 2017 digital tax accounts will include
information from employers and pension providers – easier
to allocate allowances across multiple PAYE sources
From April 2018 include savings income (only relevant
where > Personal Savings Allowance) and adjust code
◦ But can choose to opt out of coding adjustment
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Third party information
Dispute the existence of the income – notify HMRC
◦ Ideally through digital account
◦ Source will not be included in tax calculation until resolved
Dispute the amount of the income shown on the
account
◦ Contact third party and ask them to correct it
Joint accounts – should deposit taker inform HMRC?
After 2018 more sources of third party information
may be sought
◦ Dividends a likely contender – cost to business?
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