Maintaining the IPT Register: Procedures for updating the IPT register: Incorrect date of registration
In principle, the action required to deal with an incorrect date of registration for IPT is the same as that required for the correction or amendment of any information held on the register. However, if a registration has to be back-dated, then the insurer must have been providing taxable insurance contracts from an earlier date, and there is revenue due from that period. Accordingly the procedures for rectifying an incorrect date of registration are dealt with separately.
The procedures for dealing with an incorrect date of registration are explained in IPT10225.
It is, of course, possible that a registration has been effected from a date which is too early. This will usually be the result of an insurer giving mistaken information on their application to register. Where an insurer has, for example registered with effect from 1st October 1994 (the start of the tax), but did not expect to receive or write their first taxable premium until 1 April 1995, that insurer has been registered from an earlier date than is required. In theory, such a case could be dealt with by correcting the registration date. But if the insurer dealt with such a situation by filing “nil returns” for periods 12/94 and 03/95 no action should be taken. This pragmatic policy avoids unnecessary additional burdens on the insurer and the Department. If an insurer who is in this position insists on their registration date being amended to a later date than that initially given, action should be taken as explained in IPT10250.
An insurer who registered with effect from 1 October 1994 because of a genuine expectation that taxable premiums would shortly be received or written was properly registered with effect from that date, even if the expected premiums did not materialise until some time later.