Guidance

Pension schemes newsletter 100 - June 2018

Published 29 June 2018

1. Manage and Register Pension Schemes service

We launched the Manage and Register Pension Schemes service on 4 June 2018 and introduced additional features from 11 June 2018. We’re continuing to develop the new service and would welcome your feedback on this.

You can email us with this at pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Manage and Register Pension Schemes service – feedback’ in the subject line of your email.

2. Registering as a scheme administrator and applying to register a pension scheme

This is a reminder that you can only complete the process of registering as a scheme administrator or applying to register a pension scheme if you’re the pension scheme administrator. Registering and/or applying cannot be done by a third party on your behalf (and this includes pension practitioners). PTM157000 explains that certain functions including:

• making the scheme administrator declaration required under Finance Act 2004
• submitting an application to register a pension scheme
• registering as a scheme administrator on Manage and Register Pension Schemes or on the previous online service (the Pension Schemes Online service)

can only be carried out by the scheme administrator and cannot be delegated to an authorised practitioner.

This is because the pension tax legislation requires that as part of your registration/application you, as scheme administrator, must make certain declarations to HMRC. If the declaration has been made by anyone other than the scheme administrator, HMRC may reject the registration submission or the application to register a scheme. For pension schemes that are already registered HMRC may decide to de-register the scheme.

You can find more information about registering as a pension scheme administrator, including the declarations that scheme administrators must make to HMRC, at PTM151000.

You can find more information about applying to register a pension scheme at PTM032100.

If you have any concerns about this, email pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Registering as a scheme administrator/apply to register a pension scheme’ in the subject line of your email.

3. Transfers between registered pension schemes

As we explain in Transfer a pension scheme member’s savings, in cases where a member wants to transfer their pension savings to another registered pension scheme, the scheme administrator(s) of the transferring scheme can ask HMRC for confirmation of a receiving scheme’s registration status.

This is to remind you that in these cases HMRC will only confirm the registration status of a receiving scheme if both of the following apply:

• the scheme is registered
• HMRC does not hold information to suggest that there’s a significant risk of the scheme being set up or being used to allow pension liberation.

As we explain in the Transfer a pension scheme member’s savings guide, when we receive a request we’ll write back with one of the following responses.

Response 1

HMRC confirms that at this time, both of the following apply:

• the receiving scheme is registered with HMRC and is not subject to a de-registration notice
• the information held by HMRC does not indicate a significant risk of the scheme being set up or being used to allow pension liberation

Response 2

HMRC only provide confirmation of registration status when both of the following apply:

• the receiving scheme is registered with HMRC and is not subject to a de-registration notice
• the information held by HMRC does not indicate a significant risk of the scheme being set up or being used to allow pension liberation

At this time one or both of these conditions does not apply. HMRC is therefore unable to provide the confirmation you have requested.

We’ll respond to these requests as soon as we can within our usual turnaround times, however if we need to ask for more information from the receiving scheme before responding this may delay our response.

If we do not hear back from the receiving scheme or if we have any issues that cannot be resolved within 3 months we’ll issue response 2 to the scheme that made the original request. We will not provide any details of the outcome to the receiving scheme.

4. Annual allowance calculator

In Pension Schemes Newsletter 98 we explained that the annual allowance calculator is currently unavailable.

We’ve been working to update the calculator and are aiming for this to be available for you and your members to use from 6 July 2018 to calculate the member’s annual allowance tax charge. We’ll update our GOV.UK guidance with links to the calculator when this is available.

If you have any feedback on the annual allowance calculator, email us at pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘annual allowance calculator’ in the subject line of your email.

5. Relief at source

a. Annual return of information for 2017 to 2018

We want to remind scheme administrators that the deadline for submitting the 2017 to 2018 annual return of information is 5 July 2018. Failure to submit this on time will hold up interim claims for the tax month ending 5 July 2018 and any subsequent months until the information is received.

Where a submission is made, but fails processing, we still deem this to be outstanding and we will stop any subsequent interim repayment claims pending successful re-submission.

If failure occurs on the third submission we will stop all future interim claims until a further re-submission is received and is deemed successful.

You can submit your 2017 to 2018 annual information through Secure Data Exchange Service (SDES) and we’d encourage you to use this because from April 2019 this will be the only way that you can submit your return.

b. Amendments to relief at source forms and templates

To help you fill out our forms and templates correctly, we’re working on some small changes as follows:

• APSS105 – we’re making changes to box D text so that it will read ‘Details of the total amount now claimed, if different to box A or if excess relief is repayable’
  We’re amending box E text to replace the reference to paying by cheque with ‘If the amount you owe is higher than the amount you’re claiming, you’ll need to pay HMRC, go to Pension scheme administrators: how to pay tax
  
  
• APSS106 (for tax year 2017 to 2018 and earlier) - we’re amending reference to the October deadline at the beginning of the form to 5 October
  We’re making changes to box H text so that it will read ‘If the amount you owe is higher than the amount you’re claiming, you’ll need to pay HMRC, go to Pension scheme administrators: how to pay tax
  We’re also updating the ‘Help’ section at the end of the form in line with the APSS105 and APSS106 (for 2018 to 2019).
  
  
• APSS106 (use from 6 April 2018 onwards) – We’re amending the title to make it clear that this should be used for annual claims made for tax years 2018 to 2019 onwards.
  We’re making changes to box E text so that it will read ‘Details of the total amount of relief claimed or if excess relief is repayable, Total net amount claimed from HM Revenue and Customs (HMRC) B minus D’
  We’re making changes to box I so that it will read ‘Details of the total amount of relief now claimed or excess relief repayable for all members, Total amount now claimed from HMRC’
  
  
• We’ve amended the relief at source Excess relief schedule template to add in the period of claim at the top of the template
  
  
• We’re making cosmetic changes to the Electronic flat text file specification for relief at source returns

c. Government Gateway credentials required to access the look up residency status for relief at source service

We’ve been asked by some scheme administrators what credentials are needed to register with the Government Gateway in order to access the service and how to get these. You can find more information at the Registrations page and follow the instructions for either a pension scheme administrator or practitioner.

d. Further devolution

From 6 April 2019, the National Assembly for Wales will be able to vary the Income Tax rates paid by Welsh resident taxpayers. You can find more information on Welsh rates of Income Tax at Tax is changing in Wales.

In January 2019 we’ll include the Welsh residency status on the notification of residency status report for your members who live in Wales. You’ll be able to identify these members because we’ll give them a ‘C’ on the report and you should use this status for relief at source from April 2019.

So from January 2019 your notification of residency status report will include:

• ‘S’ for Scottish residency status
• ‘C’ for Welsh residency status
• a blank field – for rest of UK residency status (resident in England and Northern Ireland)
• ‘U’ – HMRC has not been able to match the member to a National Insurance number

For 2019 to 2020 only, if you’re not able to accept and operate the C status from the notification of residency status report you can default to the rest of UK.

We’re currently updating the technical specifications document for the notification of residency status report. If we previously emailed this to you, we’ll send you the revised version when it’s ready. If you want to be added to the mailing list to receive this, email pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Residency report technical specifications’ in the subject line of your email.

We’ll also be making similar changes to the look up residency status for relief at source service and we’ll keep you updated on our progress with this in future pension scheme newsletters.

e. Annual return of information for 2018 to 2019 onwards

As a result of the introduction of new residency statuses and following changes made to the relief at source regulations from April 2018, we’ll be making changes to the annual return of information for 2018 to 2019 onwards including:

• adding a column to tell us the reason that no National Insurance number has been supplied
• adding a column to tell us what rate of relief you’ve applied to your members
• deleting columns relating to employer contributions and total amount of National Insurance rebates
• renaming the column for term assurance contribution to life assurance premium contributions

We’ll provide you with full details of these changes in a future newsletter.

We know that some pension scheme administrators will not be able to make changes to their systems in time. To help with this for the 2018 to 2019 annual return of information only (due by 5 July 2019), you’ll have the option of submitting the new version of the annual return of information or the existing (2017 to 2018) version.

For the 2019 to 2020 annual return of information onwards, the new version must be used by all pension scheme administrators operating relief at source.

6. Recognised overseas pension schemes (ROPS) notifications list

We are making some small changes to the format of the ROPS notifications list.

As well as changing the journey slightly so that you’ll be able to click straight through to the list from the link, we’re also including a list of the fortnightly amendments that we make at the end of each country section so that you can see what has been added, removed or amended.

You’ll see these changes on lists that we publish from 1 July 2018 onwards.

7. Taxation of flexi access payments

We’ve recently reviewed the Employer/Pension Provider guidance on reporting these payments through Real Time Information (RTI).

We’ve revised the CWG2: Further Guide to PAYE and National Insurance Contributions. Sections 2.2.6, 2.2.7 and 2.2.8 cover the types of payment that can be made and you should report these through RTI.

We’ve also been reviewing the current process for flexible pension drawdown payments. We’ve concluded that any changes at the current time would not significantly improve the tax position for the majority of recipients of a flexible drawdown payment when compared to the process currently in place. The existing PAYE treatment of flexible pension drawdowns remains the most effective method of deducting tax in these cases and it reduces the risk of underpayments of tax arising.

We will however continue to keep the current process under review and monitor drawdowns and related claims.

8. Reporting multiple small pots payments

In Pension Schemes Newsletter 94 we explained that we’re aware that some pension scheme administrators have problems when reporting multiple small pots payments.

We initially thought that this was related to payroll IDs however we’ve continued to investigate this issue. We can now confirm that instead this relates to cases of more than one FPS for the same scheme member with the same end dates but with different payroll IDs.

We’re running a series of recovery scans that should fix this for existing payments and we’ve updated the CWG2: further guide to PAYE and National Insurance contributions with guidance for pension scheme administrators reporting these types of payments.

We’re exploring options to resolve this issue (including the possibility of running this scan on an annual basis) but to help us to understand the scale of this problem we’d like to hear from you if you’re contacted by members affected by this. In these cases email pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Reporting multiple small pots payments’ in the subject line of your email. If you provide a contact name and telephone number in the email we’ll contact you to discuss.