Alignment of dates for ‘making good’ on benefits-in-kind

The ATT has provided its response to the recent HMRC Consultation on how to align the various dates that currently exist within legislation to ‘make good’ tax on benefits-in-kind.

The Consultation came about after the Office of Tax Simplification (OTS), employers and representative bodies pointed out to the Government that there are problems with the existing rules as a number of different dates can apply depending on the type of benefit and whether the benefit is being dealt with through voluntary payrolling or via a year-end P11D form.

HMRC raised a number of questions with the purpose of bringing clarity and aligning the many different dates.

HMRC suggested the following:

  • That for company cars and company vans, the date for making good should be the end of the tax year.
  • That for car and van fuel, credit tokens and beneficial loans, the date for making good should be 1 June following the end of the tax year.

The ATT, in its response, did not agree with this two-tier approach and said that employers should not have to face yet another set of rules and deadlines to remember. The ATT suggested that the deadline for making good on any benefit should be the 6 July in all cases. As the ATT pointed out, many employers have been working to this date informally for a number of years and it fits with the current submission deadline for P11D forms. The ATT urged HMRC to simply formalise this procedure and added that the impact on the Exchequer of allowing a deadline date of 6 July would be minimal but the benefit to employers in terms of easing administrative burdens would be much more significant.

Our response can be read in full here