HMRC has published clarification on submitting forms P45 and P46 following a number of queries from employers mandated to operate PAYE in real time on or before 6 April 2013, reports Harris & Co accountancy services.
Employers have unsuccessfully tried to submit forms P45/P46 to HMRC for employees who started or left their employment in 2012-13, that is, for a period before they were mandated to report in real time. These employers have received rejections for these submissions giving error code 7818 stating "This PAYE In Year Movement submission cannot be accepted as the employer has been invited to join RTI".
These rejections have been issued correctly. HMRC will no longer accept forms P45/P46 for employers who have been mandated to join RTI on or before 6 April 2013. From the date an employer is required to operate PAYE in real time, they should not submit these forms, even for the period before RTI. For most employers this will be from 6 April 2013.
What actions you should take
If you are already mandated to submit PAYE in real time and have outstanding P45/P46 forms relevant to 2012-13 for your employees, please do not submit them.
•instead of submitting P45s you should enter the leaving date on the employee"s 2012-13 P14
•if you have already submitted your 2012-13 P35 and P14s without a leaving date then you need take no further action
•you should not include the employee on your first Full Payment Submission (FPS) or Employer Alignment Submission (EAS)
•the employment will then be automatically ceased at 5 April 2013 following HMRC"s processing of your first FPS or EAS
•you should not submit revised P14s
•you should include details of the employee in your EAS and/or first FPS and either show a date of starting of 6 April or leave this field blank
If you are not yet mandated to submit PAYE in real time you should continue to submit forms P45/P46 to HMRC up to the date of your mandation.
Further guidance is available from HMRC.