Guidance

Pension schemes newsletter 91 – September 2017

Published 29 September 2017

1. Relief at source for Scottish Income Tax

a. Annual return of individual information for 2016 to 2017

Earlier this year HM Revenue and Customs (HMRC) 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 89 and Pension schemes newsletter 90 we reminded scheme administrators that failure to submit this information by 5 July 2017 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.

We also explained in Pension schemes newsletter 90 that if you fail to successfully submit your annual return of individual information by 30 September 2017, we won’t have the information we need to send you your notification of residency status report in January 2018.

This will mean that 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.

We wrote to all scheme administrators with outstanding annual returns of individual information reminding them of this.

b. Amendments to the APSS105 and APSS106

As we explained in Pension schemes newsletter 88 we’re amending forms APSS105 and APSS106 to include information about contributions made by members who are Scottish taxpayers and the tax relief you’re reclaiming on these contributions.

You can see the draft forms in Appendix 1 draft form APSS105 and Appendix 2 draft form APSS106.

You shouldn’t use these draft forms for your repayment claims during 2017 to 2018. Instead you must use the existing APSS105 for interim repayment claims and the APSS106 for annual repayment claims.

We’ll reject any relief at source repayment claims submitted on the draft forms and you’ll have to resubmit your repayment claim using the current version of the forms.

You’ll see that the APSS106 has been updated to reflect that the submission deadline is being brought forward from October to 5 July each year. So for the 2017 to 2018 APSS106 relief at source annual repayment claim, the filing deadline will be 5 July 2018. We’re aiming to publish draft regulations later in the year covering this point.

We’ve published the draft forms for information only (not for consultation) so that you can prepare for the changes to the forms in April 2018. We may make further small amendments to these before April 2018 but will let you know if we make any big changes to these drafts.

c. Notification of individual scheme members’ residency tax status – January 2018

As explained in the Pension schemes Scottish rate of Income Tax newsletter when you’ve successfully submitted your annual return of individual information we’ll use the information you’ve provided on scheme members and match this against HMRC data to identify the correct relief at source rate to apply for 2018 to 2019.

If we can’t match the information you’ve provided against our data, your notification of residency status report will show a ‘U’ against unmatched scheme members. As a result, we’ll not provide you with an unmatched scheme members exception report.

From January 2018 onwards we’ll send you the notification of residency status report via secure data exchange service in line with the standard format so that you can apply the correct rate of relief at source to your scheme members in 2018 to 2019.

We’ll tell you the residency tax status of each of your scheme members by adding an additional field showing:

  • an S for Scottish tax status
  • a U for unmatched individuals
  • a blank field for rest of the UK

If we identify that the National Insurance number you submitted for an individual is incorrect we’ll give you the correct one. We’ll include the National Insurance number you submitted so that you can identify the scheme member from your original submission. We’ll provide more guidance on this in a future newsletter.

d. Residency tax status look-up service – user research

We explained in recent pension scheme newsletters that we’re currently developing an online service for scheme administrators to check the residency tax status of scheme members that aren’t on their notification of residency status report. For example scheme members who join the scheme part way through a tax year.

In Pension schemes newsletter 90 we asked scheme administrators who are interested in testing our residency tax status look-up service to register to use the test environment. Thank you to all of you who volunteered and have participated so far. Your feedback is invaluable and we’ll factor this in as we develop the service.

You can also volunteer to take part in our ongoing user research, by emailing us at pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Relief at source – User Research’ in the subject line.

We want to make sure that our new service is accessible to all scheme administrators and would also like to hear from you if you use assistive technologies (for example enlarged text or screen readers) or if you need additional support to use our online services.

Our user researcher, Jon Houghton, will then contact you if you are interested in helping with this research.

This is your opportunity to let us know what your needs are as users of the residency tax status look-up service. Your feedback will help us to build the best possible service.

2. New pensions online service

a. Data cleanse – lost log in details

In Pension schemes newsletter 90 it was explained that HMRC will cleanse your data before we moved your scheme and administrator details across to the new service. We asked you to log onto the Pensions Schemes Online service as soon as possible and check that your scheme administrator details are complete and up to date.

A number of scheme administrators have emailed us because they have lost their business tax account log in details. As we explained in Pension schemes newsletter 90, if you’ve lost your log in details, phone our online services helpdesk 0300 200 3600.

b. Cleansing your current Pension Schemes Online details

In Pension schemes Newsletter 90 we offered to help you check your scheme administrator records and registered pension scheme records and tell us if there are any that don’t need moving across to the new service.

If you’re 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’re 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
  • an email address

You should send requests by email to pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘List of my scheme administrator IDs’ in 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
  • an email address

You should send this information by email to pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘List of my registered pension schemes’ in 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 recent pension schemes newsletters we asked scheme administrators to volunteer to take part in our ongoing user research about pensions online. 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 by email to pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Pensions Online – User Research’ in the subject line. Our user researcher, Cay Green, will then contact you for your feedback.

This is your opportunity to let us 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.

3. Lifetime allowance scheme administrator look-up service

Earlier this month HMRC launched the lifetime allowance scheme administrator look-up service online.

Scheme administrators can check the protection status of their members using the lifetime allowance look-up service through guide Pension administrators: check your member’s protection status.

To use the lifetime allowance look-up service scheme administrators will need their members to give them their:

  • protection notification number
  • scheme administrator reference number

Your scheme members can find these reference numbers through the ‘view it online’ link in guide Pension schemes: protect your lifetime allowance.

As ever, we welcome any feedback that you have on the lifetime allowance scheme administrator look-up service. You can provide feedback by emailing us at pensions.businessdelivery@hmrc.gsi.gov.uk and putting ‘lifetime allowance scheme administrator look-up service’ in the subject line of the email.

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

As explained in Pension Schemes Newsletter 90 for taxable overseas transfers made between 9 March 2017 and 30 June 2017 inclusive you’ll need to report these and pay the tax on the AFT for the quarter ending 30 September 2017.

HMRC have updated the AFT, so from 1 October 2017 onwards you must report taxable overseas transfers quarterly (and pay the tax due) on the AFT. For the quarter ended 30 September 2017 this should include any taxable overseas transfers made between 9 March 2017 to 30 September 2017 inclusive.

5. Annual allowance

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

In Pension schemes newsletter 90 it was explained that scheme administrators, will soon be issuing annual allowance pension savings statements for tax year 2016 to 2017 to all scheme members contributing more than the £40,000 annual allowance, or the £10,000 money purchase annual allowance, to their pension scheme.

The issue of these statements is a legislative requirement.

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.

Remind members who have exceeded their annual allowance for 2016 to 2017 and who don’t have sufficient unused annual allowance to carry forward to cover the excess, that they must declare this on their Self Assessment tax return.

The deadline for submitting is:

  • 31 January 2018 online
  • 31 October 2017 for a paper return

They’ll also have to pay a tax charge unless they opt to request scheme pays. You can find more information on scheme pays in the Pensions Tax Manual (PTM056400). Your members can find more information about the different types of annual allowance and carrying forward unused annual allowance in guidance 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.

b. Annual allowance calculator – unused allowance from 2012 to 2013

Thank you to those of you who have provided feedback on the annual allowance calculator, highlighting an error in carrying forward unused allowance from 2012 to 2013 beyond 2015 to 2016.

We’re working to fix this as soon as possible and will give you an update on this in a future newsletter. Thank you for your patience.

6. Pensions tax registration

Earlier this month, HMRC published a policy paper on pensions tax registration and legislation that’ll be introduced in Finance Bill 2017 to 2018 amending Finance Act 2004.

This legislation will widen the circumstances in which we may refuse to register a pension scheme to include where:

  • the scheme is a Master Trust pension scheme and hasn’t been authorised by the Pensions Regulator
  • a sponsoring employer of an occupational pension scheme is a dormant company

Changes will also be made to the circumstances when HMRC can de-register a pension scheme, similar to the changes listed above.