The document published on the HMRC website in October entitled “Paper Substitute Returns for Self Assessment” has important consequences for Chartered Accountants involved in Self Assessment, but is not exactly a model of clarity.

ICAI, along with other CCAB bodies and representative associations, campaigned last year for a pragmatic adoption of eFiling in the context of revised Self Assessment filing dates.

As HMRC get even more exuberant about their eFiling capabilities, the use of alternative filing methods is being somewhat curtailed, but not entirely. Unfortunately the detail of the current procedures is pretty much buried in a document, a link to which is at http://www.hmrc.gov.uk/budget2007/substitute-returns.pdf.

The key points are:

Substitute versions will not be accepted from 2007/08 onwards for

• SA Individual Returns – (SA100 series)
• SA Partnership Returns – (SA800 series)
• SA Trust Returns – (SA900 series)

But what's a substitute? “HMRC will accept paper returns that have been prepared wholly, or partly, electronically provided that computer generated output is identical in appearance to the official HMRC form. HMRC is providing guidelines to software developers about what it considers to be identical. This solution is intended for the very small minority of taxpayers that do not have the option of filing online.”

Members should also note the important flexibility in the filing date for taxpayer where eFiling is not available –

“There are a small number of SA taxpayers (less than 1% of the total SA population) whose Returns cannot currently be filed online because HMRC has not yet been able to develop online facilities for their particular circumstances. Because this very small minority of SA taxpayers do not have the choice of online filing, they will be allowed to file on paper up to 31 January, without incurring any penalty that might otherwise be due for paper filing after 31 October. However, HMRC encourages all taxpayers to file early where they are in a position to do so.”

Among this constituency may be politicians and members of the judiciary and defence forces.