Guidance

Pension schemes newsletter 103 for September 2018

Updated 25 September 2018

1. Updating your scheme administrator details

In June 2018 HMRC launched the first phase of our new Manage and Register Pension Schemes service. All new pension scheme administrator registrations and new applications to register pension schemes with HMRC are made through this service.

As part of the work to prepare to migrate existing registered pension schemes and scheme administrator IDs across to the Manage and Register Pension Schemes service we’re contacting inactive scheme administrators so that only live schemes and administrators are migrated onto the service.

Last year we wrote to pension scheme administrators who had not signed in to the Pensions Schemes Online service since April 2015, to remind them to go online and update their details. However we know that there are still lots of inactive scheme administrator IDs.

We’re about to write to scheme administrators who are still shown as inactive on the Pension Schemes Online service. If you receive a letter from HMRC, please sign in to the Pension Schemes Online service and update your details. Without up to date details, we may not have enough information to move you to the Manage and Register Pension Schemes service.

If we cannot move your details across to the Manage and Register Pension Schemes service, you may not be able to access the pension schemes that you’re an administrator of on this service.

If you’ve lost your sign in details, you should contact the online services helpdesk on telephone: 0300 200 3600.

2. Operating PAYE on pension payments

HMRC wants to remind pension scheme administrators that if you pay pension benefits subject to PAYE to your members on a quarterly basis, you need to report these correctly through Real Time Information (RTI).

If you use your member’s tax code on a cumulative basis, you should use the table for month 3 for the first payment that you make to that member in the tax year, even if the payment is made in an earlier tax month.

You should then use the table for month 6 for the second payment and so on. If you use the code on week 1 or month 1 basis, use the table for month 3 for each payday.

If you use payroll software to report payroll information through RTI, please check that your software is reporting these quarterly payments correctly.

If you report quarterly pension payments incorrectly your member may pay the wrong amount of PAYE and may lead to an in-year adjustment to your member’s tax code.

You can find more information in the Pay Adjustment Tables and in the CWG2: further guide to PAYE and National Insurance contributions.

3. Master Trusts

Pension Schemes Newsletter 102 explained that from 1 October 2018 all Master Trusts must get authorisation from The Pensions Regulator.

If you’re applying to register a new pension scheme with HMRC after 1 October 2018 and your scheme is a Master Trust, you must also apply to The Pensions Regulator for authorisation at the same time.

HMRC can refuse to register a pension scheme that is a Master Trust and does not hold this authorisation.

From the 1 October 2018 if your registered pension scheme is an existing Master Trust, you must apply for authorisation from The Pensions Regulator within 6 months of that date, so that your scheme can continue to operate as a Master Trust.

If you do not obtain authorisation, your scheme will not be able to operate as a Master Trust.

If you’re the scheme administrator of an existing registered pension scheme on 1 October 2018 and your scheme status changes to become a Master Trust after this date, you must tell HMRC within 30 days of this using form APSS578. You must also apply for authorisation from The Pensions Regulator.

HMRC can de-register a scheme that is a Master Trust and does not receive or loses its authorisation from The Pensions Regulator.

More information about how to apply for authorisation is available from The Pensions Regulator.

4. Reporting of non-taxable death benefits

Pension Schemes Newsletter 102 explained that we’ve been working to resolve the problem of P6 tax coding notices that are issued in error for death benefit payments that are entirely non-taxable, and that we were aiming to fix this in September.

We now aim to fix this in October, and we’re sorry for any inconvenience this delay may cause. We will continue to keep you updated through our pension schemes newsletters at the end of each month.

To request an email when this issue is fixed please email: pensions.businessdelivery@hmrc.gsi.gov.uk putting ‘Reporting of non-taxable death benefits – fix’ in the subject line of your email.

Until this fix is in place, please follow the guidance we gave you in Pension Schemes Newsletter 78.

5. Relief at source

a. Deadline for submitting the APSS106 for 2017 to 2018

HMRC wants to remind pension scheme administrators of relief at source pension schemes that your annual claim for relief at source (APSS106) for 2017 to 2018 should reach us no later than 5 October 2018.

If your APSS106 for 2017 to 2018 is outstanding after this date, we will not repay any interim claims until you have successfully submitted this.

b. Relief at source pension schemes newsletter

In mid-September we published the relief at source for pension schemes newsletter with articles on:

• annual return of information
• notification of residency status report for 2019 to 2020
• members without a valid National Insurance number
• amendments to the APSS105 and APSS106

6. Annual allowance - pension savings statements for tax year 2017 to 2018

This is to remind scheme administrators that by 6 October 2018 you must issue annual allowance pension savings statements for tax year 2017 to 2018 to all members of your pension scheme who contributed more than the annual allowance to your pension scheme.

You can find more information about this legislative requirement in the Pensions Tax Manual at PTM167100.

An annual allowance charge will be due where a member exceeds the annual allowance across all pension schemes and does not have sufficient unused annual allowance to carry forward from previous tax years.

Please remind those members who have exceeded the annual allowance for 2017 to 2018 and do not have sufficient unused annual allowance to carry forward to cover the excess, that it’s really important they declare this on their Self Assessment tax return. The deadline for submitting this is 31 January 2019. They’ll also have to pay a tax charge.

Your members can find more information about the different types of annual allowance and carrying forward unused annual allowance in Tax on your private pension contributions.

Your members can use our Pensions Annual Allowance Calculator to check whether they need to declare and pay an annual allowance tax charge, even if they have not received a pension savings statement.

7.Trust Registration Service

a. Pension schemes that are registered with HMRC

Pension Schemes Newsletter 98 explained that if your registered pension scheme is a trust, your scheme trustees do not need to register separately on the Trust Registration Service (TRS) to meet your reporting obligations under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 when you’ve incurred a UK tax liability.

As long as you keep your details up to date on the Manage and Register Pension Schemes service or the Pension Schemes Online service, HMRC considers that the pension scheme and trustees have met their TRS obligations.

This is to remind you that if you’re the trustee of a registered pension scheme seeking a repayment on your investment income or gains and you do not have a Unique Taxpayer Reference (UTR), you must first complete an APSS146 form and then form SA970 to apply for a repayment of Income Tax that has been deducted from the investment income of your registered pension scheme.

b. Pension schemes that are not registered with HMRC

If you’re the trustee of a pension scheme that is not registered with HMRC but is set up as an express trust, that incurs a UK tax liability and you already have a UTR, you’ll need to register on TRS no later than 31 January after the end of the tax year in which you incurred a UK tax liability. This is to meet your reporting obligations under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

If you do not already have a UTR, you (as trustee) will need to register by 5 October after the end of the tax year in which the charge became due so that you can pay tax on pension investment income or gains for the first time. This is to make sure you get your UTR in time to meet the self-assessment filing deadline.