HMRC internal manual

Debt Management and Banking Manual

DMBM803040 - Time To Pay: reviewing proposals: outstanding returns

TTP is a short term concession that allows the customer breathing space in which they can bring their affairs with HMRC up to date. Where a customer does not submit returns we are unaware of their true liability and cannot be confident that an arrangement would cover the true amount that they owe.

Customer asks for TTP before the submission deadline for a return

If a customer contacts you to discuss TTP before the deadline for filing their return you should ask them how much is due. If the customer meets the conditions for TTP you can agree TTP with the customer based on the figure they provided, but you must tell the customer that the arrangement will be cancelled if they do not submit their return, or if the information on the return shows a greater amount due than the amount they have advised. The TTP should be set up on IDMS and/or the HoD system as soon as possible once the debt has been established. This will avoid late-payment penalties or surcharges being imposed incorrectly.

Customer asks for TTP after the submission deadline for a return

The time limit to send in a Self Assessment return has not yet passed

If a return is overdue then you cannot agree any TTP arrangement until the return is submitted.

Where you believe the customer intends to submit their return you can agree to take no further action to recover the debt for up to 7 days to allow the customer to submit business tax (i.e PAYE/VAT/CT) returns and up to 14 days for SA returns. You should ask the customer to pay as much as they can immediately by debit/credit card or electronic transfer of funds. If the customer is unable to pay the full amount that is due you should ask them to call back after they have submitted their return to discuss their proposals for payment of the balance. You must advise the customer that if they do not submit their return within the agreed timescale or they do not contact us back we will continue with enforcement action to collect the debt. If at this stage the customer has not a letter warning of enforcement action you must issue one.

If you believe that the customer has no intention of submitting the returns and is promising to do so in an attempt to delay enforcement action then you must not allow any additional time.

In some cases you may come across newly registered businesses that are required to file online, but who have not registered to file returns online. The registration process can take up to 7 days as the customer needs to be sent an activation code via the post. In these cases you can allow up to 14 days for the returns to be submitted.

The time limit to send in a Self Assessment return has passed

If the time limit for sending in a return has passed, you need not insist on submission of that return. This doesn’t prevent you from agreeing TTP, however, where there is a compliance enquiry for this outstanding return year, check with the compliance caseworker. You may need to make submission of the return a condition of the TTP.

The time limit to send in a Self Assessment return can vary

Be aware that a customer may have a non-standard Self Assessment filing date by which to send in their return. Also, where a determination has been raised this can also extend the relevant time limit; for more information, see SAM120033 and SAM120040.

Note: A customer can only replace a determination if filing the SA return by the later of either:

  • three years from the filing date of the return
  • 12 months from the date of the determination.

For more information, see SAM121080.

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Returns that become due during a TTP arrangement

One of the conditions of TTP is that future returns and payments must be made on time. If a customer with an ongoing TTP does not submit their returns on time then their arrangement should be cancelled. In exceptional circumstances you can consider contacting the customer prior to cancelling the arrangement.