|
Omni – Pension Schemes Online – APSS301
|
The returns can be accessed via ‘Reports,
Pension Schemes Online’, as long as you have the user-rights to prepare
the returns.
The main return for SSASs is the ‘Registered
Pension Scheme Return for Occupational Pension Schemes (APSS301)’.
The APSS301 is only needed if the SSAS receives a
notice from HMRC. However, it appears that notices have been issued to all
SSASs. The return has to be submitted, if requested, even if it is a
‘nil’ return.
If a report is needed for the tax year ended 5th
April 2007, it must be submitted by 31st January 2008. The deadline
is earlier if the scheme has wound up.
To be able to submit the return from Omni, all of the
data needs to be entered first. It is recommended that the Accounting Data
function (on the Reports menu) is run for the year to 5th April. If
all of the information for the accounts is in Omni then most of the data for
the scheme return should be available.
It is recommended that the return and the accompanying
notes are read in detail.
The scheme administrator needs to be selected on the
Trustee screen. The return can be prepared for any administrator but it can
only be submitted via Omni if the professional trustee is the Scheme
Administrator. The User ID and password are the same as used for normally
logging to the Pension Schemes Online website (these are stored under
‘Settings’).
You should decide whether all of the necessary data is
stored in the main database or additional details on assets needs to be
entered. Details on income from assets can be entered specifically for the
return – full details are in Asset Data.
To prepare the return, enter the Online Reporting
program and select ‘Pension Scheme Return, New/Amend Return’. This
displays a list of any previous drafts or any submitted returns. From here, you
can click the New button to prepare a new return or select a draft so that you
can view it or submit it.
Once the return is prepared you can view the return or
print it for checking.
You cannot amend the return itself. If the return is
not correct then you should amend the main database and/or the return asset data to reflect the correct data
and re-run.
When you have
checked the return you can retrieve the draft and then complete the
declarations. Once the declarations have been completed, the ‘Prepare for
Submission’ button is enabled. On the next screen you click submit (none
of the details can be edited). Omni then asks if you wish to proceed. If you
confirm, then Omni will communicate with HMRC’s database and obtain a
receipt.
The return is
stored and the receipt is stored at the top of the return, including an IR
mark, which identifies the submission. This receipt simply confirms that the
return was received by HMRC in a valid structure – it does not confirm
that the data has been agreed by HMRC.
Once you have submitted the return, if you find that
the data was incorrect and you need to amend the return, you can prepare and submit
another return in the same way.
If the HMRC
service is not available, perhaps due to upgrades, then HMRC will accept the
return but not send a receipt. The receipt will be shown as a message when the
administrator next logs on to the website. The receipt (IRmark) will be
supplied but then you will need to update Omni’s record of the return and
copy and paste the IRmark. This is cumbersome and so we recommend that you
avoid submitting returns when the HMRC service is not available.
The following issues are worth considering:
1. The return requires you to distinguish between assets
that have been acquired from connected parties at any time in the past
and those that were bought on the open market. As a result, you will need to
distinguish between rent received from any tenant where the property was bought
from a connected party (Section 8.6) and rent received from any tenant
(connected or not) where the property was acquired at arms-length (Section
12.8). Conventional accounts will not generally show that information.
2. Section 12 refers to all other assets not covered in
previous questions, and so details of holdings, purchase and sales of quoted
equities, gilts, unit trusts etc need to be shown. This can involve a lot of
work.
3. Interest on bank overdrafts and bank loans should not
be deducted from bank interest received.
4. HMRC have indicated that the information should not be
approximated e.g. some SSAS administrators will set up a 5 year loan with equal
repayments and assume that the interest content in each payment in a loan year
is constant – HMRC have suggested that the accurate amount of interest
for each payment in the parts of the loan year which fall in the tax year need
to be recorded precisely.
5. In 2009, HMRC issued notes on how to amend an APSS301
return. These conflicted with previous less detailed notes and required extra
amounts to be included in box 4.7 (repayments of borrowing and loanbacks,
including capital and interest). Omni was updated in 2010.