HMRC have released the final templates of the P11D and Working Sheets for the tax year 2019/20. Note that the title of the page is ‘PAYE Draft forms’, however, later on the same page it says:
These forms are final versions of P11D and P11D Working Sheets for tax year 2019 to 2020, and should only be used by software developers to help with development of their payroll software.
The Working Sheets
Number 1 – Accommodation
Where an employee is provided with living accommodation under an Optional Remuneration Arrangement (OpRA), the relevant amount treated as earnings from the employment is the greater of:
- The living accommodation benefit calculated under the normal rules, and
- The amount of cash pay foregone by the employee in relation to the provision of the accommodation
Right at the bottom of Working Sheet 1 for 2019/20, the calculation of living accommodation provided via an OpRA is explained.
Number 2 – Cars and Car Fuel
Working Sheet 2 is not to be used when a company car has been made available via an OpRA. Use Working Sheet 2b instead.
However, you will need to look at Working Sheet 2 if the modified cash equivalent value is less than the amount foregone in an OpRA situation. The starting point with OpRA, however, is always Working Sheet 2b.
Number 2b – Cars and Car Fuel via OpRA
Even if the car is provided via OpRA, the OpRA rules do not apply to cars with CO2 emissions of 75 grams per kilometre (km) or less. Working Sheet 2 should still be used to ascertain the cash equivalent.
If the car has CO2 emissions greater than 75g and the car is provided by OpRA, you are looking to calculate the modified cash equivalent rather than the cash equivalent. Use Working Sheet 2b for this calculation.
The modified cash equivalent ignores any capital contributions when calculating the price used to calculate the car benefit charge before the appropriate percentage is applied. Then, the amount used in the rest of the car benefit calculation is the greater of:
- The modified cash equivalent of the benefit or
- The amount foregone in relation to the provision of the benefit
You will need to use Working Sheet 2 if the modified cash equivalent is less than the amount foregone.
If the modified cash equivalent is more than the amount foregone, a reduction is made to the modified value in respect of capital contributions (and private use payments).
Number 3 – Vans and Van Fuel
Working Sheet 3 is not to be used when a company van has been made available via an OpRA. The Working Sheet is populated with the standard annual van charge (£3,430) and fuel benefit charge (£655).
For vans provided via OpRA, see HMRC’s guidance in the 480 HTML which explains that the benefit to be declared is the greater of:
- The modified cash equivalent of the benefit of the van, or
- The amount foregone with respect to the benefit of the van
Number 4 – Loans
Working Sheet 4 requires you to know HMRC’s Official Rate of interest for 2019/20. You are then pointed to HMRC’s guidance on the rates that apply for 2019/20 – only to find that it has not been published yet!
Whilst this form can be used for beneficial loans provided under OpRA, employers need to be aware that the benefit value is the greater of:
- The modified cash equivalent of the benefit of the loan or
- The amount foregone with respect to the benefit
The modified cash equivalent of the benefit of the loan is the amount of interest that would have been payable on the loan for that year at the official rate of interest.
So, if the amount of salary or pay foregone is greater than the interest that would have been payable on the loan at the official rate of interest, the relevant amount to be entered on the P11D is the amount forgone less the amount of any interest paid on the loan for the tax year.
Have a look at the example in the Employment Income Manual (EIM) page 44110, even though it relates to 2017/18.
Number 5 – Relocation Expenses
The old appendix 7 of the 480 (now in HTML format) is a must-read with regards to relocation expenses and payments.
Number 6 – Mileage Allowance Payments
This is the one where employers use the Authorised Mileage Allowance Payments (AMAP) rates to reimburse business mileage when using a personal vehicle. Working Sheet 6 is not to be used when Mileage Allowance Payments (MAPs) have been provided using an OpRA.
If this does apply, see EIM 44140 entitled ‘OpRA: particular issues – mileage allowance payments’.
I think that it is too early for the provision of this form given that the one for 2018/19 was not made available until the first day of the 2019/20 tax year.