Unless you deal with a significant number of trusts, it is probably only in recent months that you have started to use the HMRC’s new Agent Services Account (ASA) in earnest – despite the fact that the system completed its pilot phase in November 2017. So what have we learned about the new ASA during 2019?
A major complaint from agents is that is it not possible to see a full list of all the clients for whom they are authorised to act with the ASA.
This is, in part, a security feature. When the ASA was first launched for the Trust Registration Service, many agents didn’t want all their staff to be able to access full client lists. However, it was also partly because it was anticipated that agents would manage client lists (and staff access) through their own software.
In practice, given the range of software and bridging products used by agents, this is impractical and the agent community have been calling for client lists to be available within the ASA for some time. We understand that HMRC are considering adding what they call a flat list of clients to the ASA but not until later in 2019. A flat list means that the agent won’t be able to click through from the list to individual client records.
Linking existing services
Another common complaint from agents is that it is not possible to see when existing online services accounts have been linked to the ASA. The linking of the agent’s existing Government Gateway credentials for other services is part of the process of setting up the ASA.
HMRC are working on the inclusion of a small box on the ASA to confirm when existing Government Gateway accounts are indeed linked. In the meantime, if an agent tries to relink an account which is already linked, they should receive a message confirming the link is already in place.
Authorising new clients
The link between the ASA and any existing Government Gateway account to which it has been connected is dynamic – but only in one direction. It is dynamic in that clients which are added or removed from existing online services will effectively be added or removed from the ASA but clients who are only added to the ASA will need to be separately added to any existing services that the agent also needs to access on their behalf. Accordingly, it may be more efficient to add new clients to existing services first, and then rely on the dynamic link to provide access via the ASA.
A concern which was recently raised on the Agent Forum is that agents cannot have both an existing online agent service account and the ASA open at the same time in the same internet browser. For example, logging into the self-assessment service for agents in a new tab will result in the agent being logged out of their ASA on another tab.
The current workaround to avoid repeated logging in and out of the old and new systems is to log into each service in a different browser.
Agents based outside the UK must follow separate guidance to set up their ASA which was originally published in February and has since been updated.
The challenge for many such agents is demonstrating compliance with AML supervision as not all countries require tax agents to have an AML registration. At a recent meeting with professional bodies, HMRC said that no application will be rejected purely on the basis of a lack of AML supervision where the agent’s home country did not require it.
Another confusing aspect of the ASA is that services such as the Trust Registration Service are not accessed by logging into the ASA itself, but by going to a specific location on GOV.UK and logging in there with the agent’s ASA credentials. Agents may need to create new bookmarks to make sure that they can find their way to the relevant log-in points.
Agents and their clients need to be aware that once they have signed up to MTD, the client’s VAT registration certificate will no longer be visible in either the ASA or existing online services for the agent or client. Since information on the certificate might be required in future, it may be worth printing this information out or saving it elsewhere before signing up. We are advised that HMRC are aware of and working on resolving this problem.
From 1 April 2019, any business which is newly required to register for VAT will also have to consider if it needs to comply with MTD requirements. If so, then the two processes are dealt with separately, with the VAT registration carried out in the usual manner, followed by the steps for signing up for MTD once registration has been completed. HMRC are looking at developing a single combined service, but it’s unlikely to arrive anytime soon.
There are estimated to be around 200 different tax forms which taxpayers might need to submit to HMRC. Currently some must be drafted on paper, some via structured, online forms, and some via the Government Gateway. Originally the intention was to move many of these forms into the ASA. Such ‘intelligent’ i-forms would then be accessed by agents by first logging into their ASA and, as a trial, a number of forms were moved into the ASA in 2018. However, earlier this year HMRC announced that it would no longer be pursing this approach and instead is looking to develop a consistent suite of ‘Government’ or ‘g-forms’ instead. The access route will no longer require the agent to log in via their ASA. Those forms which had been moved to within the ASA have now been moved back out again.
As a separate service from existing online services, the ASA has a separate page on GOV.UK where details of any known issues or downtime for maintenance can be found.
More details on the ASA and MTD more widely can be found on the ATT website.
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Ten things we’ve learnt about the Agent Services Account this year