Real time information (RTI) has had a bumpy start. In brief these are the major problems and work-arounds discovered so far.
Annual PAYE Schemes
If you expect to pay all of your employees just once in the tax year, and all on the same date, you can register your PAYE scheme with the Tax Office as an annual scheme.
HMRC’s official guidance was that annual schemes only had to submit one FPS (full payment submission) under RTI for the month the payments were made, no nil EPS (employer payment summary) were required for the other 11 months of the year.
However, in practice any PAYE schemes registered as annual in 2013/14 are not acknowledged as ‘annual’ by the RTI system. This means nil EPS returns have to be submitted for every month when employees are not paid.
The RTI system will be fixed on 17 May 2013 to cope with registrations of annual PAYE schemes, but you need to wait until after that date to tell HMRC you want the PAYE scheme to be annual. In the meantime carry on submitting nil EPS returns.
Forms P45 and P46
Under RTI forms P45 and P46 are not required to be submitted, even if the starting or leaving date of the employee fell before you were mandated to use RTI. If you have employees who started or left in 2012/13, and you didn’t submit a P46 or P45 before 6 April 2013 you should:
- If possible, enter the leaving date on your ex-employees’ 2012/13 form P14.
- Do not submit revised P14s for 2012/13 if these have already been submitted.
- Don’t include the ex-employee on your first FPS or EAS (employer alignment submission). The employment will be then be automatically ceased at 5 April 2013.
- Include details of the new employee in the EAS and/or first FPS and either show a date of starting of 6 April or leave this field blank.
You don’t need your employee’s NI number in order to pay him, or to submit the FPS report under RTI.
If the worker arrives without an NI number, you should complete the other data fields for that worker; name, address, and (if you need to check the worker’s eligibility to work in the UK) – the worker’s passport number. You should leave the NI number field blank if no NI number has been provided. The worker should be told to apply for an NI number as soon as possible.
You can run an NI number verification request (NVR) under RTI, but this should only be attempted once you have sent the first FPS under RTI. If HMRC finds an incorrect NI number on the FPS you will be informed. In that case the worker can be asked to check if the NI number they have provided is correct. This can be done by using the HMRC form CA5403.