How to set up client authorisations using forms 64-8, FBI 2 and CH995 for Self Assessment, Corporation Tax, PAYE, CIS, VAT and High Income Child Benefit Charge.
As a tax agent, adviser or accountant, you must be formally authorised by an individual or a business to deal with HM Revenue & Customs (HMRC) on their behalf. HMRC won’t be able to discuss your client’s personal or financial information with you if they haven’t received this formal authorisation.
In most cases getting formal authorisation is straightforward. The easiest way to set up and manage your client authorisations is to use HMRC Online services. If you choose not to set up your client authorisations online, you can ask your client to complete a paper form.
Applying for client authorisation using paper forms
The easiest way to set up and manage your client authorisations is to use HMRC Online services. This saves you and your client having to complete paper forms and makes it easier for you to manage authorisations for all your clients online. But if you choose not to use HMRC Online services to set up authorisations, you can ask your client to complete a paper form.
Agent authorisation (whether by paper form or online) will not transfer any of your client’s legal obligations to you. Your client remains responsible for all aspects of their dealings with HMRC.
Agent codes and agent reference numbers
For some taxes you need an agent code (or agent reference number) before you set up client authorisations.
For Self Assessment, Corporation Tax, PAYE for employers and CIS clients, you must have an agent code. This applies whether you are using a paper form or the online authorisation process.
For VAT and VAT EU Refunds, you don’t need an agent code to set up authorisations using form 64-8, but some agents do need an agent reference number to set up online client authorisations.
Authorisation using forms 64-8 or FBI 2
Your clients can use form 64-8 to authorise you to act on their behalf for:
- individual, partnership and trust tax affairs (which includes National Insurance)
- requests for information to help calculate the High Income Child Benefit charge
- Corporation Tax
- PAYE for employers
- CIS for contractors
- tax credits (see separate section later in this guide)
- VAT (see separate section later in this guide)
If you know that your client wants you to act on their behalf for more than one tax or process, you can get authorisation for all of them at the same time by selecting the appropriate boxes on form 64-8. If you start to act for an aspect of a client’s affairs not covered by the original form 64-8, you’ll need to submit a new one.
Please note: if your client wants you to act in relation to CIS, they should make a clear note on the form (or attach a separate letter).
Personal representatives can also use form 64-8 if they want you to deal with the estate of a deceased person in certain circumstances (see the section below).
The completed form should normally be sent to the Central Agent Authorisation Team, but there are some exceptions (see later in this section).
When the registration process is complete, HMRC may start sending letters and forms to you - but sometimes HMRC will write to your client as well as or instead of you. Depending on which tax you’ve been authorised for, you may also be able to view statements online, returns submitted, payments made and what is owed.
If your client has authorised this, you will start receiving their Self Assessment statements. But your client will continue to receive National Insurance statements unless they have asked HMRC to defer payment.
You can find out when to expect a reply to your form 64-8 using HMRC’s Where’s my reply? tool.
When to send form 64-8 to another HMRC office
Your client should send the completed form 64-8 to HMRC at the above address unless:
- the authorisation relates solely to Corporation Tax (in which case you should send it to the HMRC office that deals with your clients’ Corporation Tax)
- your client is already dealt with by the Manchester Expatriate Team, in which case you should send it to that team
- your client is already dealt with by the High Net Worth Unit (previously the Complex Personal Return Team), in which case you should send it to that team
- the form has been specifically requested by an HMRC office, in which case you should return it there
- the authorisation relates to a charity, in which case you should send it to the charities correspondence team in Bootle
- the authorisation relates to trust tax affairs, in which case you should send it to the trusts and estates team in Nottingham
- the form accompanies an R40 repayment claim (see below)
R40 repayment claims
If you’re sending form 64-8 with an R40 repayment claim for the National Claims Office in Leicester, you should send both forms to that address. But if your client has a PAYE source of income you should send them to:
HM Revenue & Customs
PO Box 4000
Form FBI 2: authorisation to use the PAYE/CIS for Agents online service
You can use the PAYE/CIS for Agents online service to set up client authorisations. This service enables you to handle your client’s PAYE for employers and/or CIS affairs online.
If you don’t choose to use the online authorisation process, your client can authorise you to transact online on their behalf by completing the paper form FBI 2 instead.
Form FBI 2 can only be used to authorise the accepting of information over the internet. If you want to handle other PAYE for employers or CIS matters for your clients, your client must also complete from 64-8.
Authorisation for VAT
If your client’s business is already registered for VAT, please send the completed form 64-8 to the Central Agent Authorisation Team.
If your client’s business is not registered for VAT, please submit the application for registration before you send in form 64-8. This will enable you to quote your client’s VAT number on form 64-8. HMRC will still deal with you if they have any questions about your client’s VAT registration application.
When form 64-8 is not appropriate for VAT
VAT online service
Your client can use form 64-8 to authorise you to act for them for VAT, but this doesn’t authorise you to transact with HMRC online. If you want to transact with HMRC online on your client’s behalf - for example submit their VAT Return - you also need to set up an online client authorisation through the VAT for Agents service.
Please note: if your client has more than one accountant or tax adviser acting for their business, and they want one of them to submit their VAT Return online, they will need to be careful about how they tell HMRC about this. The accountant, adviser or bookkeeper that your client wants to submit their return online must use the VAT for Agents online service to set up an online authorisation for VAT. Any other agent authorisations must be made using paper form 64-8.
Non-Established Taxable Person (NETP)
If, for VAT purposes, a client is a Non-Established Taxable Person (NETP) - defined as a trader who is not normally resident in the UK and who doesn’t have a business address in the UK - they’re entitled to appoint either a ‘tax representative’ or a ‘tax agent’ to act on their behalf. There is a different process for appointing agents and tax representative in these circumstances. Please follow the link below for more information.
Option to Tax
VAT traders who wish to appoint an agent or other third party to make an Option to Tax (taxing any land or buildings being supplied) on their behalf are required to submit written confirmation to HMRC that the third party is authorised to do so. HMRC would also like to be notified if you withdraw that authority.
Registering or making changes to VAT groups
Your client must use form VAT 53 to authorise you to register a VAT group or make changes to an existing group on their behalf. If you’re registering a business for VAT and setting up a VAT group at the same time you can send form VAT 53 with the application. If you’re using HMRC Online services you should attach the form to the online application.
Please note: form VAT 53 doesn’t authorise you to deal with HMRC on behalf of the VAT group for any other matters.
Authorisation for tax credits
You can’t set up client authorisations online for tax credits. Instead your client must complete form 64-8 and send it to HMRC.
HMRC will continue to write to your clients about their claim, but can deal with you in writing or by telephone on specific matters.
Please note joint tax credits claimants must both sign form 64-8.
If you are making a claim for tax credits at the same time as submitting form 64-8, please do not post them together. You should send form 64-8 to the Central Agent Authorisation Team.
Applications for tax credits should be sent direct to the Tax Credit Office at:
Tax Credit Office
Please note: you can only apply for agent authorisation for tax credits where there is an existing claim or if you’re confident that a claim is due. For tax credits applications made within 12 months of form 64-8 being submitted, you can have your authority applied to the client record by contacting the Agent Priority Line. After that, a new form 64-8 will be needed.
Authorisation for the High Income Child Benefit charge
Your client can use form 64-8 to authorise you to request specific income and Child Benefit details about their partner/ex-partner.
Your client should send the completed form to the Central Agent Authorisation Team.
When form 64-8 is not appropriate
If your client wants to authorise you to deal with other Higher Income Child Benefit charge matters, they must complete form CH995 and send it to the Child Benefit Office.
Form CH995 allows you, on your client’s behalf to:
- ask about any Child Benefit payments they’ve received
- tell the Child Benefit Office of their decision to stop or restart their Child Benefit payments
- discuss matters relating to their decision with the Child Benefit Office on their behalf
Once authorisation has been set up the Child Benefit Office will be able to deal with you in writing, by telephone or online for these matters. But the Child Benefit Office will continue to send correspondence to your client regarding their Child Benefit.
Personal representatives and agent authorisation
Personal representatives can use form 64-8 if they want you to deal with individual PAYE, Self Assessment and National Insurance affairs for the estate of a deceased person. When completing form 64-8 they should:
- put the name of the person (known as the signatory) who is authorising you to act on behalf of the estate in the first box on the left. This is usually the personal representative. The signatory should also add their signature next to their name
- enter the address of the signatory in the ‘Give your personal details or company registered office here’ box
- include the date of birth and National Insurance number of the signatory just above the ‘For official use only’ on form 64-8
Please note: the National Insurance number or Unique Tax Reference (UTR) of the deceased person should be included in the boxes on the right.
The completed form should be sent to the Central Agent Authorisation Team.
More than one agent acting for the same client
If your client has more than one agent acting on their behalf they must complete the appropriate form for each agent. For example, if your client has an agent for Self Assessment and another for Corporation Tax they must make it clear on each form 64-8 what service each agent is being authorised for.
Please also see the section above for information about multiple agent authorisations for VAT.
PAYE for employers
For PAYE for employers a client may want more than one agent to act on their behalf and deal with payroll issues. HMRC’s PAYE for employers system is only able to send out information such as tax code notices P6 and P9 to one agent. Clients who have more than one agent dealing with their payroll matters must choose which one ‘lead’ agent they want to receive this information.
If you are becoming the ‘lead’ agent, you must be authorised using either the agent online authorisation service or by completing form 64-8. Clients can authorise HMRC to send information to you either online or by using form FBI 2.
If your client is already using an agent who continues to act for them as the ‘lead’ agent, please do not submit a form 64-8 for your authorisation as this may result in the ‘lead’ agent’s details being overwritten.
If your client wishes to nominate you as a second agent, they should send a letter to HMRC with details of the secondary authority so that your records can be updated accordingly.
And remember, if you only wish to file information online on behalf of your client, and do not need HMRC to communicate with you directly, you can do so without submitting a form FBI 2.
Helping HMRC speed up the paper authorisation process
There are a number of ways that you can help HMRC make the paper agent authorisation process faster. But wherever possible, you should use HMRC Online services instead of a paper form. The online process is fast, safe and secure and you can be certain that HMRC has received your request.
Use the latest on-screen forms
You can fill in forms 64-8 and CH995 on screen. This will save you time and you can send it to your client for their signature with the fields pre-filled. It will also help the form to be processed accurately using information you provide.
For this reason, it’s a good idea to make sure you use the most recent version of the forms and discard any previous versions you may have.
General hints to speed up processing of paper authorisations
You can help speed up the processing of authorisation by:
- not sending a covering letter with the completed form unless you have a specific question relating to the processing of the form
- sending the 64-8 and other correspondence or forms (if you need to) to the right address
- not sending duplicate authorisation requests (whether online or by paper) - if the authorisation hasn’t been processed in the appropriate timescales you should call the appropriate helpline to check its progress
- contacting the Agent Account Manager team if your form 64-8 hasn’t been processed in the appropriate timescales and you sent it somewhere other than the Central Agent Authorisation Team
- making sure the 64-8 or CH995 has an original signature and is dated by the client - don’t send photocopies as they can’t be processed
- making sure you’ve included relevant agent identity codes
- not using form 64-8 to apply for an agent code or reference number
- making sure you give all the information required for each entity covered by the 64-8 (individual, claimant, company, employer etc)
- stapling forms CWF1 or SA1 and 64-8 together, if submitting the forms at the same time
- knowing that form 64-8 only sets up a client authorisation - it doesn’t register your client’s business with HMRC (ticking the ‘If UTR not yet issued tick here’ box won’t create a Self Assessment record)
- making sure the UTR or National Insurance number is included if your client already has a Self Assessment record - otherwise your details can’t be added to your clients record
- making sure you include a PAYE employer’s full PAYE reference number (including tax district number) if you’re applying for authorisation to deal with them