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Correspondence with HMRC regarding submission of VAT returns, estimation, MTD and the default surcharge regime.

31 March 2020      Andrea Marshall, Tax Specialist

Andrea sent an email to Dave Cannon at HMRC last week seeking clarification on a few points regarding submission of VAT returns, estimation, MTD and the default surcharge regime.

Please find her questions in itallics and Dave Cannon’s response in bold below.

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I am receiving queries from members regarding submission of VAT returns whilst working remotely.    The concerns appear to centre on being able to prepare accurate VAT return figures (as a result of having problems accessing all or some of the finance systems at home) and being able to submit the return via MTD at home.  Although universities will not be submitting returns for a few weeks, there will be subsidiary returns to submit.

In the instances where our members are experiencing problems, I should be grateful if you would:

  • Confirm that VAT returns still need to be submitted (from what I have seen that is the case);

Return submission: Yes, returns must be submitted on time, only payments can be deferred.

  • Advise whether the VAT return figures can be estimated without prior approval from HMRC (for example, when it comes to submitting the April 2020 VAT return, using the figures from the April 2019 return, after removing any distortive items; or accruing for VAT based on expected throughput, if detailed analysis is not available from parties within the university) and then corrected on a future return;

Estimation: All the usual estimation rules apply at the moment i.e. there is no change to the requirement to gain HMRC agreement if they need to submit estimated figures. 

  • Advise whether HMRC will accept alternative methods of submission to MTD, such as emailing or phoning through VAT return figures and if so, what HMRC email addresses or phone numbers should be used;

MTD submission: I think this will come down to individual circumstances and therefore not possible to answer in general terms.  I think that customers will need to call the helpline below.

COVID-19 helpline

Number 0800 024 1222

Open 8am to 4pm Monday to Friday

  •  Advise whether the default surcharge regime is being suspended during this time.

Default Surcharge: I am not aware if this is the case or under consideration however I will advise if I hear anything.



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