HMRC have now published their guidance on real time information (RTI) reporting of payments to harvest casuals and casual beaters. This guidance confirms that the operation of PAYE and NIC for harvest casuals remains as previously agreed between HMRC and the NFU. Payments will however need to be reported on RTI returns and this guidance sets out how and when payments will ordinarily have to be reported to HMRC.
Reporting requirements
From 6 April 2013 payments to all employees must be included on RTI returns to HMRC. This includes payments to harvest casuals and casual beaters, regardless of whether or not PAYE and NIC deductions are required. This is a significant departure from the previous process where names, addresses and amounts paid were separately reported on an annual form P38. It is important to note that this will also mean collecting more information from harvest casuals, including National Insurance numbers.
When to report payments
The original RTI rules required employers to submit a return on or before every payment to an employee. The NFU worked hard to highlight that there are circumstances where this requirement would be impossible to comply with, as in the case of daily paid harvest casuals. As a result amendments were made to the legislation. This allows additional time for reporting payments to employees such as daily paid harvest workers where certain conditions apply. The amendment allows payments to be reported up to 7 days after the day the payment is made. Whilst this is not as long as the NFU called for it does mean that payments can be reported on a weekly basis. However HMRC’s guidance suggests that it will still be necessary to submit a separate return for each day that payments are made.
The further temporary extension for reporting payments
The NFU has always argued that the on or before payment reporting requirement under RTI will result in significant additional cost and burden for many smaller employers. We are pleased that following further constructive discussions, HMRC announced a temporary relaxation for employers with fewer than 50 employees. This applies until 5 October 2013 and should allow employers who find it difficult to report every payment to employees at the time of payment, to instead report the payments when they next run their regular payroll. For those engaging daily paid harvest casuals this will mean being able to report payments when the next payroll for regular employees is run, whether this is weekly, fortnightly or monthly.
What to do if you have any questions?
If you have specific questions regarding the RTI reporting requirements please contact NFU CallFirst on 0870 845 8458.
RTI reporting difficulties -a call for evidence
We are pleased that HMRC have agreed to work with employer representatives, including the NFU, over the next few months. HMRC have suggested they will consider whether they can make improvements to real time reporting which address our concerns, without compromising the benefits of RTI or the success of the Department for Work & Pension's Universal Credit.
We therefore wish to hear from any members who, for any reason, are unable to meet the reporting requirements set out by HMRC in their guidance. We would also like to receive any examples of where RTI reporting requirements impose significant administration or cost burdens on members businesses, whether this relates to reporting payments to harvest casuals or to any other employees. If you are able to supply this evidence please send details to TWljaGFlbC5QYXJrZXJAbmZ1Lm9yZy51aw==