HMRC has issued a consultation on various proposed changes to the filing and payment process – in particular a reduction in the time limit for filing and payment from 30 days to 14 days. However, the introductory blurb suggests that the government has already decided to make this reduction, having announced it in the Autumn Statement 2015. Their main concern is therefore to seek views on whether and what issues might arise as a result of the reduction.
In our opinion, the process of preparing the forms to report complex commercial transactions is complicated and can be extremely time-consuming. In time-pressured transactions, it is often not possible during the course of the transaction to engage with the approval of the significant amount of information which needs to be included on the returns. It is not unusual for transactions to be completed where required information about a property (for example, details of leases/subleases) is simply not known and has to be ascertained following completion.
We also believe that the decision to reduce the filing and payment window to 14 days might exacerbate the number of returns submitted with incomplete information and the significant processing costs incurred by HMRC will be further heightened. Whilst we file our returns electronically, currently over 40% of paper returns are submitted with “errors”. We feel that substantial simplification of the forms and of the amount of information required should be undertaken in order to mitigate this risk and we hope that the government will take this on board when the result of the consultation is announced.
The full title of the consultation is: “Stamp duty land tax: changes to the filing and payment process”. The consultation closes on 7 October and can be found on the website.