Employment tax deadlines

Submit paper or electronic forms P46 (car)
Deadline for action: 2 February 2019, 5 April 2019 and 3 May 2019

Issue: Details of employees being provided with or ceasing to be provided with company cars for the previous quarter should be provided to HMRC using form P46(car). These details are usually submitted electronically. The completed online form can, however, be printed out and submitted in paper form to HMRC by the relevant date. This method cannot be used for replacement vehicles.

Action: P46(car) forms (electronic or paper) covering the quarter to 5 January 2019 are required to be received by HMRC by 2 February 2019. P46(car) forms covering the quarter to 5 April 2019 are required to be received by HMRC by 5 April (electronic) or 3 May 2019 (paper).

Onshore & offshore employment intermediaries – quarterly reports
Deadline for action: 5 February 2019 and 5 May 2019

Issue: Employment intermediaries are required to make quarterly reports to HMRC. The quarterly reports for the quarters to 5 January 2019 and 5 April 2019 are due by 5 February 2019 and 5 May 2019 respectively. These reports require a considerable amount of information regarding all workers provided to their clients, including those operating via personal service companies (PSC), and related payments where the intermediary or their payroll operator did not operate PAYE.

Action: Quarterly employment intermediary reports must be made using HMRC’s report template and submitted using HMRC’s online service. Automatic penalties arise if the report is late or incorrect, with the amount of each penalty depending on the number of offences in a 12 month period: £250 (first), £500 (second) and £1,000 (third and later). The penalty clock is reset once there has been a 12 month period without a late or incorrect return.

PAYE and NICs reporting and payments
Deadline for action: Monthly – from 19 (or 22) February 2019

Issue: To avoid interest and penalties, employers should make a Full Payment Submission (FPS) to HMRC at the time they pay their employees and pay over deducted tax and NICs by the due date. Tax and NICs deducted under PAYE should be paid by the 19th of the following month if paid by cheque, or the 22nd if paid electronically. The FPS and, if applicable, an Employer Payment Summary (EPS) should also be submitted by the 19th of the following month.

Action: Employers should submit their FPSs and EPSs (including, where applicable, a report of the apprenticeship levy due and allowance claimed) and pay their PAYE tax and NICs on time. Advance payment should be made where the payment date falls on a weekend. Late payments attract interest at 3.25 per cent and late filing gives rise to penalties of between £100 and £400 per month, depending on the number of employees.

Employers that have incurred penalties have 30 days to appeal if appropriate.

CIS reporting and payment dates
Deadline for action: Monthly – from 19 February 2019

Issue: Written statements to subcontractors, CIS300 monthly returns of payments made by contractors to subcontractors, and payment of the CIS tax deducted, should be made on a monthly basis. 

Action: Contractors should provide a written statement to every subcontractor from whom a deduction has been made and submit their CIS300 returns by the 19th of the following month to avoid late filing penalties. To avoid interest and late payment penalties, CIS tax deducted should be paid by the 19th of the following month if paid by cheque, or the 22nd if paid electronically. Advance payment should be made where the payment date falls on a weekend.

Check for new advisory fuel rates
Deadline for action: 1 March 2019

Issue: HMRC revises the advisory fuel rates every quarter. These rates may be used when an employer reimburses employees for fuel for business travel in their company cars, and when an employer requires employees to repay the cost of fuel used for private travel in such vehicles.

Action: Employers should review HMRC’s advisory fuel rates each quarter to ensure that they are using the current rates. If employers reimburse such costs at different rates, records must be kept that support the rates used.

Voluntary payrolling of benefits in kind (BIKs)
Deadline for action: 5 April 2019

Issue: Employers should register online with HMRC, if they have not already done so, to payroll BIKs. The payrolling rules apply to all benefits except living accommodation and beneficial loans. Benefits payrolled under these rules do not need to be reported on forms P11D.

Action: Employers that are not already payrolling benefits that wish to do so for the 2019/20 tax year and thereafter should register with HMRC as soon as possible so that they can commence payrolling from 6 April 2019. Employers should first consider if systems and procedures support this, and how levels of administration could be affected. Consideration should also be given to the way any changes affect and are communicated to employees.

2019 loan charge for disguised remuneration schemes
Deadline for action: 5 April 2019

Issue: Loans provided by certain persons to employees or traders may give rise to tax charges if they remain outstanding immediately before the end of 5 April 2019. Under rules targeting disguised remuneration arrangements, income tax and National Insurance contributions will arise (generally under PAYE where the loan is to an employee) where certain loans are outstanding at 5 April 2019, unless an exclusion applies. The loan charge will not apply where a contract for settlement with HMRC has been signed by 5 April 2019.

Action: Affected employers and individuals who do not wish to suffer the loan charge should ensure that settlement is reached with HMRC (where possible) or loans are repaid by 5 April 2019, or before the approved repayment date in the case of approved fixed term loans.

2019 loan charge – provision of information to employers
Deadline for action: 15 April 2019

Issue: Loans provided by certain persons to employees may give rise to reporting requirements if any amount is outstanding between 17 March 2016 and 5 April 2019. Under rules targeting disguised remuneration arrangements, the person making the loan and the employee receiving the loan must ensure that prescribed information is provided to the employer where certain loans were outstanding between 17 March 2016 and 5 April 2019.

Action: The relevant information must be provided to the employer by 15 April 2019 in order that the employer can meet its PAYE obligations, including paying over the amounts due to HMRC by 19 (or 22) April, if a disguised remuneration charge arises on 5 April 2019. The employee must also report the information to HMRC between 6 April 2019 and 30 September 2019, unless an appropriate agreement is reached with HMRC covering all liabilities arising before 1 October 2019.

For more information please get in touch with David Williams-Richardson, Mark Morton, or your usual RSM contact.