Job Retention Scheme applications for employees with no National Insurance Number or a temporary National Insurance Number

25 Jun 2020

The Government is deferring the first reporting deadlines under the International Tax Enforcement (Disclosable Arrangements) Regulations 2020 by six months. This will provide taxpayers and intermediaries dealing with the impacts of the covid-19 pandemic with additional time to ensure that they can comply with their obligations. This is in line with the approaches announced by a number of other implementing jurisdictions.

HMRC‚ s International Exchange of Information Manual has been updated with details of how the deferral will work in practice. You can find the guidance here.

The Government will amend the Regulations to give effect to this deferral. The amended Regulations may not be in force by 1 July 2020, but no action will be taken for non-reporting during any period between 1 July and the date that the amended Regulations come into force. There is therefore no expectation that reports will be made in July.

In light of this deferral, HMRC will not be switching on the IT system that will be used for reporting on 1 July. The IT system will be made available to taxpayers and intermediaries to report arrangements ahead of the new, deferred deadlines and we will use the additional time to work with taxpayers and intermediaries on this.

HMRC intends to publish guidance shortly to help businesses in their preparations to meet their reporting obligations.