Guidance

Pension schemes newsletter 90 – August 2017

Published 31 August 2017

1. Annual allowance

a. Annual allowance calculator

Thank you to everyone who has provided feedback on the annual allowance calculator. We’re continuing our work to review and update the calculator and your feedback is still important to us.

You can provide feedback to us directly on the GOV.UK pages or by Email: pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Annual allowance calculator’ as the subject line.

We are grateful for your help with this. We aim to release an updated version of the annual allowance calculator in the autumn and we’ll update you when this is live in a future newsletter.

b. Pension savings statements and annual allowance charges for tax year 2016 to 2017

This is to remind you that as scheme administrators, you’ll soon be issuing annual allowance pension savings statements for tax year 2016 to 2017 to all scheme members contributing more than their annual allowance to your pension scheme.

The issue of these statements is a legislative requirement of Finance Act 2011.

An annual allowance charge will be due where a member exceeds their annual allowance across all pension schemes and doesn’t have sufficient unused annual allowance to carry forward from previous tax years.

Please remind those members who have exceeded their annual allowance for 2016 to 2017 and don’t have sufficient unused annual allowance to carry forward to cover the excess, that it’s really important that they declare this on their Self Assessment tax return.

The deadline for submitting this is 31 January 2018. 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 the GOV.UK guide Tax on your private pension contributions.

Your members can use our online tools and calculators to help check whether they need to declare and pay an annual allowance tax charge, even if they haven’t received a pension savings statement. These can be found at Pension savings annual allowance calculator.

2. Relief at source for Scottish Income Tax

a. Secure data exchange service (SDES) enrolment

In Pension Schemes Newsletter 89 we reminded you that if you’re a pension scheme administrator (PSA) of a relief at source pension scheme who doesn’t currently submit your annual return of individual information electronically, you must send us some details. This is so that we can help to enrol you onto SDES.

We also explained that we needed this information by 31 July 2017 to give us time to co-ordinate your enrolment with our SDES project team.

We’ve set out the information we need you to provide in Appendix 1 of this newsletter.

Whilst lots of you have contacted us with your details, there are still PSAs of relief at source schemes who haven’t provided us with this information.

If you haven’t provided us with your details please send the information in Appendix 1 of this newsletter to us as soon as possible using Email: pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Relief at source - SDES enrolment details’ as the subject line.

It’s really important that PSAs of relief at source pension schemes are enrolled onto SDES. This is because in January 2018 we’ll send you a notification of residency tax status of your individual members on SDES so that you can give the right amount of tax relief to your members and claim the right amount of repayments from HM Revenue and Customs (HMRC).

We need this information by 30 September 2017. Failure to provide us with this information and enrol onto SDES will mean you will not receive a Notify RAS report and you’ll have to default to give relief at source at the UK rate for all your members for 2018 to 2019, unless you choose to use the residency tax status look up service.

In Pension Schemes Newsletter 88 we explained that we’d use this information to help you enrol onto SDES. To give us more time to register you onto the SDES system, we’ll register you on Secure Electronic Transfer (SET) first. You won’t be charged for this.

Once we’ve processed your information we’ll provide you with a secure reference number on SET that you’ll need to complete the enrolment process and you’ll keep your secure reference number when we migrate you to SDES.

We’ll contact you with full instructions when we start this process and you can find more information on this in Appendix 2 of this newsletter.

We have received a number of queries from PSAs asking if outsourced companies should be enrolled separately for SDES. We can confirm that whoever files the annual return of individual information must enrol for SDES either through the above process or through automatic migration if already registered for SET. For example, a separate company outside of your organisation who does not use SET but submits an annual return of individual information on your behalf by other means (for example, on a CD or USB), must enrol for SDES.

Scheme administrators who don’t provide this information by 30 September 2017 and aren’t enrolled on SDES in time, will not receive the Notify RAS Report in January 2018.

b. Residency tax status look up service - access to test environment

In Pension Schemes Newsletter 88 we asked scheme administrators who were interested in testing the residency tax status look up service to email us for access to the test environment.

We can confirm that this test environment is now available to everyone, along with the look up service technical specification information. We recommend that your IT developers register to use the test environment.

When you or your IT developers access the link and view the list of available APIs, you must select and register for both the ‘customer matching’ and ‘relief at source’ APIs. You’ll be asked to name your service and should select something that is specific to your company, for example ‘Company ‘A’ RAS Look up’, so that you have a unique name within the test environment.

You can use the help and feedback links within the test environment if you have any queries.

c. Residency tax status notification – format of January 2018 Notify RAS Report output file

We told you in the Pension Schemes Scottish Rate of Income Tax Newsletter that we would send scheme administrators an output file from January 2018 in line with the standard format of the annual return of individual information that you submit and that we’d correct the National Insurance numbers and provide you with the residency tax status of your members.

We are working on this output file and have had some queries about the format of the file and whether delimiters will be used to separate the data fields. We can confirm that we will use delimiters. These may be in the format of a ‘pipe’ (also known as a vertical bar) or a comma but we are still working to determine the format.

For example: ,Dr, Any, Person, QQ123456C,

We will provide more information in future pension schemes newsletters, however please let your IT department or IT developers know that we’ll use delimiters in the output files we send to you.

d. Applying the residency tax status in cases of transfer

For all transfers for members of relief at source schemes, you should use the residency tax status as provided by HMRC to give the right amount of relief at source.

However, we’ve received a number of queries from PSAs about transfers between registered pension schemes or PSAs and when to use the residency tax status look up service.

A member transfers between 2 schemes that you’re scheme administrator of:

• if one (or more) of your scheme members transfers from one scheme that you’re the scheme administrator of into a different scheme that you are also the scheme administrator of and you already hold details of their residency tax status, you may use this to provide the correct level of relief at source to that member in the new scheme
• if you take over as scheme administrator of an existing scheme and the scheme and members stay the same, we’d expect that all the information about the scheme and its members would be passed over to you as the new scheme administrator; if this is the case, you may use the residency tax statuses as passed over by the ceasing scheme administrator

In both of these scenarios, you may choose to use the residency tax status you or the ceasing scheme administrator already hold, or you may choose to check the residency tax status of these members using the residency tax status look up service.

For all other transfers between schemes you can use the residency tax status look up service so that your members receive the correct amount of relief at source, or you should give relief at source at the UK rate as default.

e. Annual return of individual information for 2016 to 2017

Earlier this year we issued notices requiring pension schemes operating relief at source to submit their annual return of individual information for 2016 to 2017 to HMRC by 5 July 2017.

The deadline for submitting the 2016 to 2017 annual return of individual information has passed but there are still a number of these returns outstanding.

In Pension Schemes Newsletter 88 and Pension Schemes Newsletter 89 we reminded scheme administrators that failure to submit this information by the deadline will hold up any subsequent interim repayments pending receipt of the outstanding information. If you make a submission, but this fails processing, we still consider your annual return to be outstanding and will stop any subsequent interim repayment claims pending successful re-submission.

If failure occurs on your third submission, we’ll stop all future interim repayments until we receive a further re-submission that is successful.

You must successfully submit your 2016 to 2017 annual return of individual information by 30 September 2017.

This is because we’ll use this information to send you your Notify RAS Report January 2018 so that you can give the right amount of tax relief to your members and claim the right amount of repayments from HMRC.

Failure to provide us with this information and enrol onto SDES will mean you’ll not receive a Notify RAS report and you’ll have to default to give relief at source at the UK rate for all your members for 2018 to 2019, unless you choose to use the residency tax status look up service.

HMRC continue to work closely with PSAs to help them meet their obligations.

You can find more information on relief at source repayments and the member information we need relating to relief at source in the GOV.UK guide Pension administrators: Relief at Source annual information returns.

f. Annual return of individual information

From April 2018 HMRC will no longer accept paper versions of the annual return of individual information, also known as the RPSCOM100(Z).

Between April 2018 and April 2019 you can continue to submit the return by USB, CD or DVD. If you use any of these methods please ensure the media is securely packaged, password protected and sent by tracked post. Or you can submit your annual return by email or though our new digital SDES service.

From April 2019 you’ll only be able to submit your annual return of individual information through SDES.

3. Qualifying recognised overseas pension schemes

a. APSS262 reporting transfers to qualifying recognised overseas pension schemes

In Pension Schemes Newsletter 88 we reminded PSAs to use the latest version of the APSS262 form to report transfers to qualifying recognised overseas pension schemes. However, we’re still receiving old APSS262 reporting overseas transfers made from 9 March 2017.

Pension Schemes Newsletter 88 explained that we’ll reject any old APSS262 forms reporting overseas transfers made from 9 March 2017 because they don’t contain the additional information that you’re now required to provide. We reminded you that if you don’t provide the information required under the new pension tax rules within the relevant timescales, you may be liable to penalties. This includes cases where you’ve used an old APSS262 to report details of a transfer made from 9 March 2017 that we have rejected and have sent you a request to resubmit.

You can find the latest versions of all our forms online at Pension scheme forms.

b. Reporting the overseas transfers charge on the Accounting for Tax Return (AFT)

In Pension Schemes Newsletter 85 we explained that from 9 March 2017, in addition to the checks that you make to ensure that an overseas transfer is a recognised transfer you’ll also need to check if the overseas transfer charge applies.

If the overseas transfer charge applies to a transfer, you must report this on your AFT. This is to remind you that for taxable overseas transfers made between 9 March 2017 and 30 June 2017 you’ll need to report these and pay the tax on the AFT for the quarter ending 30 September 2017.

4. Event report – save and submit

We’ve had a number of queries from scheme administrators and practitioners about using the save and submit function of the event report.

To use the save and submit function you should follow the steps below:

• log in and start the event report as usual, selecting PSTR and tax year, and enter details of any event you want to report to date
• select ‘return to event report status overview’ using the link
• select ‘save and exit this event report’ from the links in your summary view of the report items
• read and confirm that you accept the conditions on the disclaimer that appears by ticking the box and then click ‘ok’
• you’ll see a page telling you of the last date for submission of that event report, select and click the link ‘complete save and exit of this event report’

In your event report overview page, the event report for that scheme should show as ‘in progress’. Your PSTR, scheme name, tax year and report status (in this case ‘in progress’) will display, and you’ll have the option of continuing with that report or viewing all reports for your scheme.

Your report should remain accessible through your event report overview page or your event reporting page for that scheme. You’ll be able to access this and it will remain open until you complete and submit your event report to HMRC.

If you follow these steps you won’t see this as an incomplete task on your welcome page.

5. Lifetime allowance look up service for PSAs

We are continuing to work on the lifetime allowance PSA look up service. We hope that this will be available shortly for you to use and will keep you updated on when the service will be available.

6. New pensions online service

In Pension Schemes Newsletter 89 we explained that we’re working on a new service for pension scheme registration and scheme administration.

a. Moving existing scheme administrator details to the new service

In Pension Schemes Newsletter 89 we explained that pension scheme registration and administration will move onto the Pensions Online Digital Service so that we can improve the service for PSAs.

We said that we planned to migrate your existing registered pension schemes as well as your scheme administrator IDs across to the new service from April 2019.

However, to allow existing administrators to register new schemes on the new service, we have decided to transfer existing scheme administrator data onto the new service by April 2018, a year earlier than we said in Pension Schemes Newsletter 89.

We know that there are lots of scheme administrator IDs that are inactive. We’ll cleanse the data before we move this across so we only migrate up to date details to the new service.

We need your help with this. All PSAs should log onto the Pensions Schemes Online as soon as possible and check that their scheme administrator details are complete and up to date.

This is because we may not have enough information to move you to the new service if you haven’t logged onto the current online service since April 2015,

If we can’t move your details across to the new service, you’ll have to register as a new user on the new service from April 2018.

If you’re a PSA who has never been attached to a scheme, or you are on Pension Schemes Online but aren’t currently active, we don’t intend to move your details over to the new service although you’ll be able to register as a new user on the new service from April 2018.

However, if this applies to you and you want your scheme administrator details to be transferred over to the new service, you should send the reasons why you need to keep your current details using Email: pensions.businessdelivery@hmrc.gsi.gov.uk, and put ‘Administrator ID retention’ as the subject line.

If you have lost your log in details, you should contact our online services helpdesk on Telephone: 0300 200 3600.

We’d also ask practitioners who file reports and returns on behalf of scheme administrators to remind their scheme administrators to take action.

b. Cleansing your current Pension Schemes Online details

So that we only move across details that you need, we need you to check all of your scheme administrator records and all of your registered pension scheme records and tell us if there are any that do not need moving across to the new service.

We can help you do this ahead of April 2018 (for scheme administrator records) and April 2019 (for pension scheme records).

If you are a scheme administrator and you’re unsure of your scheme or administrator ID details, you can ask us for a list of:

• your scheme administrator IDs
• the schemes of which you are the administrator

You must send us a separate request for each of these and provide the following information.

List of scheme administrator IDs

You must provide:

• the scheme administrator name
• an address including postcode
• a contact telephone number and email address

You should send requests to Email: pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘List of my scheme administrator IDs’ as the subject line.

List of registered pension schemes attached to your scheme administrator ID

You must provide:

• the scheme administrator name
• the scheme administrator ID
• a contact telephone number and email address

You should send this information to Email:pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘List of my registered pension schemes’ as the subject line.

We’ll validate the information you provide and may ask for more information before we provide any scheme or scheme administrator details.

You should use the information to check your records and tell us of any scheme administrator IDs or schemes that you no longer need.

c. User research

In Pension Schemes Newsletter 89 we asked scheme administrators to volunteer to take part in our ongoing user research. Thank you to all of you who volunteered and participated so far, your feedback is invaluable and we’ll factor this in as we develop the service.

You can volunteer to take part in our user research, by sending your request to Email: pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Pensions Online – User Research’ as the subject line. Our user researcher, Cay Green, will then contact you for your feedback.

This is your opportunity to let HMRC know what your needs are as users of our new pension online digital service. Your feedback will help us to build the best possible service.

Appendix 1 - SDES enrolment information and contact details for the support team

I wish to enrol onto SDES. Please find the required details below:

An asterisk (*) denotes mandatory information

Organisation name
Organisation registered address (this should be same as the address registered under Companies House)
Primary contact details:
Name
Role
Main contact number
Additional contact number
Email address

Primary Security or IT Contact (if different to above)
Name
Role
Main contact number
Additional contact number
Email address

Secondary Contact
Name
Role
Main contact number
Additional contact number
Email address

Secondary Security or IT Contact (if different to above)
Name
Role
Main contact number
Additional contact number
Email address

Appendix 2 - SDES onboarding guidance for PSAs

Introduction

This onboarding guidance has been specifically created to support PSAs who have been directed to onboard with SDES by the Relief at Source project team.

It is important that this document is reviewed in full, and only used by PSAs who are currently liaising with the Relief at Source project. The guidance in this document shouldn’t be used after 31 December 2017.

For detailed information on the SDES service, please refer to the SDES Technical Specification document or the Pension Schemes Scottish Rate of Income Tax Newsletter.

The following pages describe the enrolment process that PSAs must follow in order to use SDES in January 2018.

Overview on enrolling onto SDES

SDES is replacing an HMRC file transfer service - SET. During the replacement, there are specific dates when individual components are replaced, with the enrolment process being one of these components.

Due to the need for all PSAs to be able to use SDES from January 2018, there are a large volume of new users to be onboarded in a relatively short space of time. It is therefore not possible to wait until the new enrolment process for SDES is completed; onboarding of PSAs must begin sooner.

Utilising the existing SET enrolment process

The existing SET service has an enrolment process that is currently still functional. As SDES will automatically migrate all enrolments from SET to SDES at the appropriate point in time, it is therefore possible to allow PSAs to complete their enrolment using the SET process, and gain immediate access to SDES at the switch over date.

The high-level process is as follows:

Step 1 - PSA organisation information provided to HMRC’s Relief at Source Project Team

Prior to receiving this guidance, it is likely you have already provided your organisation’s details to HMRC’s our Relief at Source Project Team.

If you have not yet carried out this step and have received this guidance through other means, send the required information in Appendix 1 to Email: pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Relief at source – SDES enrolment details’ as the subject line.

Step 2 - The HMRC Support Team enters your organisation’s details into the SET system

Step 3 - HMRC Support Team emails PSA with guidance and secure reference number

The HMRC support team will send you an onboarding email, using the contact email address provided. The email contains guidance information on SDES, including onboarding, and service functionality. In addition, your organisation’s secure reference number (also referred to as a SET reference number) is provided.

Step 4 - PSA prepares to complete enrolment

We recommend that you review all the guidance provided on SDES, and carry out any necessary preparation activities.

Step 5 - PSA calls HMRC Support Team to obtain activation code

When you’re ready to proceed, please call the HMRC Support Team on Telephone: 03000 597 222 between the hours of 9:00am to 5:00pm, Monday to Friday, to obtain your activation code.

This will be used in conjunction with your secure reference number to complete the onboarding process online

Step 6 - PSA completes SET online enrolment journey

Step 7 – Information of live SDES Service is provided to PSAs

Further Information

Will I need to provide different information to use the SET enrolment process?

No. All the information you’ve been requested to provide for SDES remains the same. The only difference is that you’ll be using a different journey on the Government Gateway website to complete your enrolment.

How does the enrolment automatically move across to SDES?

When you complete your enrolment online, information is stored in a database that associates SET with your organisation. When SDES goes live, the Project Team will automatically utilise this data to permit your organisation access.

Does the enrolment for SET require me to purchase certificates and encryption software?

You won’t need to purchase certificates or encryption software for SET. The enrolment process can be completed without these items. These would only be required if you need to transfer a file using SET.

Will there be test capabilities when migrating to SDES?

Yes. SDES will retain the same ‘proving file’ test capability currently provided on SET; please refer to SDES Technical Specification document or the Pension Schemes Scottish Rate of Income Tax Newsletter for full information.

Further Questions

If you have any questions or concerns, please email the Relief at Source Project Team at pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘SDES enrolment’ as the subject line.