Debt and return pursuit: PAYE RTI: payments: effective date of payment (EDP)
Postal payments by cheque must reach HMRC no later than the 19th of the month following the end of the tax month or quarter to which it relates.
Electronic payment must clear into HMRC’s bank account no later than the 22nd of the month following the end of the tax month or quarter to which it relates.
Unlike BROCS, which can only apply one due date (19th), ETMP can apply different due dates for postal (19th) and electronic payments (22nd).
Because ETMP can distinguish between postal and electronic payments and then apply the relevant due date when calculating late-payment interest or monitoring defaults for late-payment penalties, it is not necessary to amend the EDP of electronic payments posted to 2013-14 and onwards on ETMP.
This means that, from 2013-14, payments on ETMP show an EDP of the date HMRC received credit for the payment. Any electronic payment with an EDP of 20th to the 22nd is therefore regarded as having been received by the due date, and will not incur late-payment interest or count as a default when considering late-payment penalties.
Payments reallocated from ETMP to BROCS
If an electronic payment is allocated to an employer’s PAYE Contract Account on ETMP for 2013-14 and then reallocated to an earlier year on BROCS, no automatic adjustment is made to the EDP.
As such, any electronic payments reallocated from ETMP to BROCS with an EDP of 20th to 22nd, appear on BROCS as being received late when in fact they were made by the due date. In these circumstances, the EDP should be adjusted to the 19th.