As part of the recent security review, HMRC have made some changes to the processing of agent authorisation and registration for Self Assessment (SA). As January approaches and a fast turnaround of agent authorisation is required by many agents, it is important that members in practice are aware of HMRC’s changes in procedures. HMRC have issued a briefing note on this. The key points to note are:
Where to send forms
All 64-8s should be sent to CAAT unless stated otherwise on the back of the form.
National Insurance Number (NINO) or a Unique Taxpayer Reference number (UTR)
As a minimum, a NINO or a UTR must be provided on every form 64-8 sent to the CAAT in Longbenton.
Procedure for all clients where the 64-8 is sent to the CAAT
From 1 December 2009 forms 64-8 for individuals received by the HMRC CAAT with neither a National Insurance Number (NINO) nor a Unique Taxpayer Reference number (UTR) will be returned to the agent with a covering letter asking that they be fully completed.
Procedure for Clients needing to register for SA
The form 64-8 must be accompanied by either a form SA1 or CWF1 before an SA record will be created. The latest versions of these forms can be found on the HMRC website using the ‘Find a form’ link from the homepage.
In all cases, HMRC have asked agents to ensure that their agent code is quoted on form 64-8.
Procedures for Clients dealt with by CAR Expats
The form 64-8 for clients dealt with by CAR Expats should be sent to the Manchester Expat Team in accordance with the instruction on the back of the form. The 64-8 should contain the NINO/TRN (Temporary Reference Number) and/or UTR where known/relevant. Where any of these references is missing, please add the client's date of birth to assist in tracing the PAYE record. For non SA/PAYE cases, please attach form SA1 to the 64-8 and send to Manchester.
The message from HMRC regarding forms handled by the CAAT in Longbenton states:
Change to Handling of Agent Authorisation Form 64-8
HMRC have been working with representatives in the tax agent community to ensure that customers remain safe when using online services and electronic communication generally. One area where HMRC have identified a potential risk of identity fraud is in the completion of agent authorisation form 64-8 and registration for SA.
In order for HMRC to ensure that the individual who is being allocated to a specific agent is a legitimate customer, form 64-8 needs to be completed as fully as possible. A specific area of risk is where the form 64-8 is submitted with neither a National Insurance number nor a Unique Taxpayer Reference. To minimise this risk, forms received by HMRC after 1 December 2009 with neither of these items of information will be returned to the agent, for completion, with a covering letter. There will be no reduction in the level of service for the resubmitted forms so HMRC remain confident that they can be processed without undue delay once returned.
In the past HMRC have also accepted the submission of a 64-8 with the ’If UTR not yet issued’ tick box completed as being a request to register the customer for Self Assessment. Unfortunately the risk to both HMRC and the tax agent of fraud in these cases is such that in future HMRC will insist on the completion of a form SA1 or CWF1 before creating an SA record. HMRC will action the authorisation request for other heads of duty but will require submission of the completed SA1 or CWF1 before issuing a UTR and completing the SA registration process.
In the vast majority of cases this level of information is routinely provided by tax agents and no problems will arise. HMRC apologise in advance for any inconvenience that the change of policy may cause in the short term but hope that tax agents will be able to complete the forms and authorities as fully as possible and will understand the steps we need to take to reduce the risk of fraud for all parties involved.
Customers can have their National Insurance number confirmed in writing by contacting the National Insurance Helpline 0845 915 7006. Opening Hours 8:00am to 5:00pm Monday to Friday.
Finally, please help us by ensuring that your agent code is quoted on form 64-8. This will enable us to deal with your application as quickly as possible, reduce the risk of duplication and ensure that the authorisation appears on the correct agent client list.