Guidance

Relief at source pension schemes newsletter - December 2018

Published 5 December 2018

1. Notification of residency status report for 2019 to 2020

a. Updates to the notification of residency status report

For notification of residency status reports from January 2019 onwards, we’re adding an additional residency status to tell you if your member has a Welsh residency status for relief at source schemes.

Your members’ residency status will be shown in an additional field to the original information you submitted on your 2017 to 2018 annual return of information and will be one of the following:

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

We’ll also give you the correct National Insurance number if the National Insurance number you submitted for an individual was incorrect on your annual information return. We’ll give you this in an additional column on your 2019 notification of residency status report. However unlike last year, we will not correct the National Insurance number if only the suffix is different.

You can then identify the scheme member from your original submission and correct the National Insurance number on your records.

We will circulate the technical specifications for the notification of residency status report shortly and this will give you more information about the format of the January 2019 report. If you want to be added to this mailing list and have not already contacted us, email pensions.businessdelivery@hmrc.gsi.gov.uk and put ‘Residency report technical specifications’ in the subject line of your email.

We’re sorry that we’ve been unable to circulate the technical specifications sooner. If you’re not able to accept and operate the C status from the notification of residency status report in January 2019, for the 2019 to 2020 tax year only you should default to the rest of UK residency status.

b. Receiving your notification of residency status report

In January 2019 we’ll tell you the residency tax status of your scheme members, so that you can apply the correct rate of relief at source to your scheme members in the tax year 2019 to 2020.

From mid January 2019 you’ll be able to download your notification of residency status report from the Secure Data Exchange Service (SDES) and your report will be based on data from your 2017 to 2018 annual return of information.

To receive your notification of residency status report, you must be enrolled on SDES and have submitted your 2017 to 2018 annual return of information. If you are not enrolled for SDES and/or have not submitted your annual return of information, you will not receive a notification of residency status report in January 2019.

We’ve contacted pension scheme administrators who’ve submitted an annual return of information for 2017 to 2018 but who are not enrolled onto SDES and we’ve been working with them so that they’re ready to receive the report through SDES.

If you’re concerned because you have not enrolled onto SDES you can email reliefatsource.administration@hmrc.gsi.gov.uk as soon as possible and we’ll explain what you’ll need to do.

c. When you can download your notification of residency status report

In January 2019 we’ll email when your file is available for you to download and you’ll have 6 days to download this (144 hours starting from when we make the file available to you for download). Check that your email address is up to date on SDES and if not you should update this to avoid delay in accessing your report. We’ll send you a reminder by email too. If you’re expecting an email from us but do not think you’ve received one, check your junk folder in your email account.

You should email us at MDTSSETCustomerManagement@hmrc.gsi.gov.uk if you:

• cannot open your report because the file is corrupt
• have not received your report by the end of January 2019 and you submitted your annual return of information for the previous tax year
• did not download the report in time

d. If you do not receive a notification of residency status report

If you do not receive a report you can use the look up service to check the residency tax status for single or multiple members or default to the UK basic rate for your members. From April 2019 the look up service will include Wales as a search result.

If you do not have a residency status for a member by the time you claim relief at source on their first contribution, you must treat them as having a ‘rest of UK’ residency status. You must not apply a tax rate based on the member’s address.

Once you’ve used a residency status to claim relief at source for a member, you must use this for the whole of the tax year.

2. Annual return of information for 2018 to 2019

In the Relief at source pension schemes newsletter - September 2018 we explained that we’ll be making changes to the annual return of information for 2018 to 2019 and we’ll only accept your return if you submit this through SDES. In an appendix to this newsletter we also included information about structuring your 2018 to 2019 annual return of information. In the new year we’ll be publishing new registered pension schemes electronic flat text file specifications and a new registered pension scheme relief at source spreadsheet based on the appendix, alongside the current versions on GOV.UK.

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

So that we know which version you’ve used, you’ll need to use a different naming convention for each version.

Submitting your annual return of information using the current version

If you choose to submit your annual return of information using the current version, you can use the existing format for naming your return. You can find guidance on this on the registered pension scheme relief at source spreadsheet or the registered pension schemes electronic flat text file specifications.

Submitting your annual return of information using the new 2018 to 2019 version

If you choose to submit your annual return of information using the new version, you must change the way you name the sub references on your return. When using the new format instead of the sub reference running from 01 they must run from 21, even if you only have one sub reference.

So if you usually submit a file with a sub reference 01, this would become:

• P0000_21_001_001_2019

Returns with multiple sub references must use sub references running from 21 onwards instead of sub references running from 01.

For example:

• P0000_01_001_001_2019 becomes P0000_21_001_001_2019
• P0000_02_001_001_2019 becomes P0000_22_001_001_2019
• P0000_03_001_001_2019 becomes P0000_23_001_001_2019
• P0000_08_001_001_2019 becomes P0000_28_001_001_2019
• P0000_10_001_001_2019 becomes P0000_30_001_001_2019

Changing the way you name the sub references does not affect how you name the batches. If you are submitting two or more batches under the same sub reference you should use this format:

• P0000_21_001_002_2019
• P0000_21_002_002_2019

Make sure you name all your annual returns correctly. Using the current naming convention on a return submitted in the new format will result in the return being rejected and may affect your future relief at source interim claims.

3. Scottish Budget

The Scottish government will publish their Draft Budget 2019/20 on 12 December 2018. We’ll publish information in future newsletters if the Scottish Budget affects your relief at source claims.