RTI and "on or before"

payrollpro

I know that HMRC have attempted to clarify the "on or before" rules for payroll and RTI next year but I wonder what happens when we don't actually know when the payment date is? HMRC have rightly stated that the date the funds become available/owned by the employee is the payment date for the purposes of RTI, so that covers the directors and discounts "drawings" as the trigger and that makes sense to me.

However, we do not always know when the DLA is affected by the funds, do we? if we report on their behalf and then find they never made the transfer, is that a default?

I am wondering if in fact the RTI work for director/employees needs to be done by the company and not us in order to make sure the reporting is done at the right time, what do others think?

Payrollpro

ExcelAnt

Hiya,

Seems to be a hotly debated subject across Accountingweb and elsewhere.

My two cents is basedd in theory not reality, but surely the wage element for Directors is either
1)a bank payment on a set monthly date,
2) or a slow dripfeed into the DLA (again monthly) with the transfer being made at the end of the year.
3) Additionally some directors/business are operating on a one time only payment at year end.

In all instances the nature of the transaction is making the funds available therefore a return is required. the fact that cash has not been transferred out the business in point 2) is irrelevant the nature of the transaction requires a return.

Apologies if I missed your point here. What do you mean by default? The loan is simply still outstanding in the accounts and the Director has been "paid" in the eyes of the PAYE system

The complication seems to come in for the yearly situation as monthly returns are required showing nil values. Check accountigweb for further to see if the point has been clarified there.

StuartW

Hi - AAT is collecting responses and concerns from its members regarding RTI, so I'm going to forward this to the team in question if you don't mind. It's important we're able to let HMRC know where concerns lie.

FYI, if you have any further thoughts you'd like AAT to take into account you can email them to RTI@AAT.org.uk.

Stuart