MTD for ITSA: What businesses and accountants need to know

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The MTD for ITSA timeline has shifted. Find out how HMRC’s new phased approach will affect all small businesses.

Digitalisation of tax is a huge focus for the UK government. Making Tax Digital (MTD) for VAT is already running and demonstrating the benefits of digital working for many businesses.

The next milestone will be rolling out MTD for Income Tax Self Assessment (ITSA) for self-employed individuals and landlords.

MTD for ITSA was previously due to be introduced from 6 April 2024 for sole traders and landlords with an annual qualifying income over £10,000.

HMRC has recognised this requires a significant change in working while we’re in a challenging economic climate. It has therefore decided to change the mandation threshold as well as shift to a phased roll-out from 2026.

In this article we’ll cover all the updates you need to know as well as who can get involved in early testing over the next year.

What is MTD for ITSA?

Making Tax Digital for Income Tax is a new way of reporting income and expenses which will replace the Self Assessment returns for sole traders and landlords.

It will require the taxpayer or their agent to:

  • use software that is compatible with Making Tax Digital for ITSA
  • keep digital records of business transactions
  • send quarterly updates to HMRC which summarise those business transactions
    • Separate quarterly updates will be required for UK property, foreign property and each of your self employments
  • provide details of any tax and accounting adjustments and reliefs to finalise your taxable income from property and self-employment
  • provide details of other income sources and other information such as tax allowances and reliefs you wish to utilise that would have previously been included on your self assessment tax return
  • confirm the information you have provided is ‘complete’ by making a ‘Final Declaration’ by 31 January the following year.

Where are we at now with MTD for ITSA?

It was announced in a written ministerial statement on 19 December 2022 that the launch of MTD ITSA would be pushed back, and the income threshold increased.

At the same time, the government announced a review of smaller business needs, to consider whether it makes sense to bring those under the £30,000 income threshold into MTD.

HMRC is now taking a phased approach:

  • self-employed businesses and landlords with an income greater than £50,000 will be required to comply with MTD for ITSA from April 2026
  • those with an income greater than £30,000 must comply from April 2027.

The inclusion of general partnerships has been postponed with a commitment to introduce MTD at a later date.

The aim is to provide more time for businesses, particularly those with the smallest incomes, to adapt to the new ways of working while also allowing HMRC more time to thoroughly test the process for all users.

It is right to take the time to work together to maximise the benefits of Making Tax Digital for small businesses by implementing the change gradually. It is important to ensure this works for everyone: taxpayers, tax agents, software developers, as well as HMRC.

Victoria Atkins, Financial Secretary to the Treasury

What else has changed with MTD for ITSA?

At the Autumn Statement on 22 November 2023, the Outcome of the Making Tax Digital Small Business Review confirmed MTD for ITSA will not be extended to sole traders and landlords with income less than £30,000 for now, but the government will continue to review this decision.

The changes to the scope of MTD for Income Tax, primarily the increase in the threshold from £10,000 of annual qualifying income to £30,000 means that the impacted taxpayer population has been cut by more than half and now stands at 1.75 million.

Here are the other changes announced at the update:

The period covered by each quarterly update within a tax year will move from standalone to cumulative. This means that taxpayers will not need to resubmit a historic update in the event there is an error or an amendment and instead the most recent quarterly update will overwrite the preceding one. This is expected to significantly simplify the process of making quarterly updates especially when historical errors are identified.

The End of Period Statements for each source of income will no longer be required. Those of you who have followed the developments of the MTD policy will remember that originally there was an additional submission between the quarterly updates and the finalisation of the return in order to confirm the completeness of the self-employment and rental income. In reality, this submission was somewhat redundant because you could continue to adjust the income until the finalisation of the tax return. It added unnecessary complexity and ambiguity for taxpayers and as such HMRC has removed it to help simplify the process.

There will be relief for landlords of jointly owned property. They can opt to keep less detailed digital records and opt out of submitting expenses within quarterly updates. The question of how landlords of jointly owned property would comply with the record-keeping and submission requirements of MTD has plagued the programme since its inception. So HMRC has again simplified the design by introducing the easement and effectively taking the problem off the table.

HMRC will develop a solution to allow multiple agents to engage in the process for a single taxpayer. The so-called ‘multiple agents’ conundrum has been another key issue in the MTD design. Essentially, the move to quarterly reporting AND end-of-year reporting for multiple income streams could result in taxpayers wanting to use more than one authorised agent. That’s not something HMRC’s backend systems can currently support, but it has committed to implementing a solution ahead of mandating that will support this.

Specific exemptions will be introduced for foster carers and individuals without a National Insurance number.

The Furnished Holiday Lettings Tax Regime will be abolished from 6 April 2025. This will help to again simplify reporting.

Together, these changes address many of the unknowns and concerns around the MTD for Income Tax design and policy that led to the delay.

HMRC now believes it is in a much better position to move the programme forward to a testing phase.

What is the private beta and how does it work?

HMRC had previously paused its pilot testing of the programme prior to the delay announcement in December 2022. But it relaunched private beta testing of MTD for ITSA on 22 April 2024 and is currently encouraging agents to sign up. It is also possible for taxpayers to sign up directly.

Testing has been relaunched as a ‘private beta’ for tax year 2024/25 meaning that testing will be at a smaller scale.

The programme director of Making Tax Digital, Craig Ogilvie, told attendees at the Festival of Accounting and Bookkeeping in March that HMRC is focusing on “quality not quantity” for tax year 2024/25.

It’s also worth noting that whilst HMRC has addressed many of the key issues around the policy and design of the programme, the functionality will be implemented iteratively.

This means that whilst all the required functionality to support all taxpayers will be in place for April 2026 it won’t all be in place for day one of the beta testing.

Therefore, not all taxpayers are eligible to sign up for the 2024/25 private beta testing.

To be eligible for private beta, you (or your client) must:

  • have a tax year that runs from 6 April to 5 April (or 1 April to 31 March if your software can support this)
  • ensure personal details are up-to-date with HMRC
  • be a UK resident
  • have a National Insurance number
  • have submitted at least one Self Assessment tax return
  • be up-to-date with tax records and payments.

You cannot sign up voluntarily if you:

  • have a High Income Child Benefit Charge (HICBC)
  • have a payment plan with HMRC
  • are a partner in a partnership
  • claim Married Couple’s Allowance
  • claim Blind Person’s Allowance
  • are bankrupt or insolvent
  • are a Lloyds underwriter, a minister of religion or an MP
  • receive income as a foster carer or are in a shared lives scheme
  • receive income from a trust
  • receive income from a jointly owned property
  • receive income from a furnished holiday let
  • are subject to a compliance enquiry
  • use ‘averaging’ arrangements because your profits vary between years (for example you are an artist, farmer, or writer).

There are a few important things to consider for anyone thinking about voluntarily taking part in the 2024/25 private beta testing:

  • You will not be able to claim carry-back losses, change accounting period or change accounting method during the period of testing.
  • You can join part way through the tax year but will have to retrospectively submit quarterly updates from the beginning of the year. So if you’re not quite ready to join now you can still sign up later in the year.
  • If you change your mind and no longer want to take part in the beta testing, you can leave and return to the usual self assessment process (however you will still need to join MTD from April 2026 if you are mandated.)
  • HMRC has confirmed that those taxpayers participating in the beta will be subject to the new MTD for Income Tax penalty regime which is a ‘points’ based system similar to the regime for MTD for VAT with penalties for both late filing and late payment.
  • However, HMRC has confirmed you will not incur any filing penalties for late submission of quarterly updates during the testing period. This exemption does not apply to the online ‘Final Declaration’ due 31 January. This means you can still accumulate points under the new penalty system for submitting your online ‘Final Declaration’ late.
  • You will still be subject to late-payment penalties while taking part in the beta, and these will be calculated using the new MTD method. This method calculates late-payment penalties as a percentage of outstanding tax and will apply if your payment is more than 15 days overdue (whereas the current regime begins after 30 days). So depending on the amount you owe, this could result in significantly higher penalties.
  • You will have the benefit of extra support from HMRC, which in a letter to agents said “by joining the testing programme, you will have access to the dedicated MTD Customer Support Team to help you successfully transition to MTD for Income Tax and handle any issues. For those who join testing in 2024 to 2025, the team can also support the individual, or their agent, with some of the individual’s wider personal tax affairs (individual PAYE and Self Assessment matters) for the 2024 to 2025 financial year.”

The other key element to a successful beta is the availability of third-party software, without which, participants won’t be able to make submissions.

HMRC is hopeful that software providers will get on board early and support the programme to ensure successful end-to-end testing and ensure taxpayers and their agents have choice within the market.

The providers and their products that are currently participating and have been through the recognition process are listed on the HMRC software choices pages.

What will happen after private beta?

If the current criteria rule you or your clients out from taking part in the private beta, make sure to check back next year as many restrictions will be dropped to expand testing further from April 2025.

Testing will ramp up in April 2025 to a large-scale public pilot testing programme. This is in advance of mandated participation from April 2026 for sole traders and landlords with income above £50,000.

HMRC hopes to encourage voluntary early adoption of MTD. It will continue to collaborate with users and address challenges throughout public pilot testing.

What accountants need to do now

First, you’ll need to discuss these changes with every client who will be impacted by MTD for ITSA.

If you think a client would make a good candidate for the 2024/25 private beta testing, make sure to step them through the process and explain the implications of joining the voluntary programme.

Once you’ve talked them through it, make sure to get their consent. You will need this consent before you begin moving forward with the registration process below.

All agents need an Agent Services Account (ASA) to be able to access MTD services and make submissions on behalf of their clients. Think of this as similar to the Government Gateway login.

You will only need one ASA for your firm. Once you have one you can set up your staff with administrator or assistant logins to use the account.

Your firm may already have signed up for an ASA when you registered to submit MTD for VAT returns or Trust Registration Service returns.

The next step is to ensure you have compatible accounting software to be able to submit quarterly updates on behalf of your clients.

Sage Accounting is currently one of the few products on HMRC’s list of approved providers that is ready to use right now if you wish to sign up clients for beta testing.

Once you have MTD compatible software you can sign up eligible clients for MTD for ITSA. Here is the information you’ll need for the sign-up process:

  • client’s full name
  • date of Birth
  • National Insurance number
  • business start date or the date your client started receiving income
  • accounting method (cash or accrual basis)
  • the tax year your client would like to start using MTD for ITSA.

Once completed you’ll need to provide the client’s authorisation.

You can do this either by signing in to the Agent Services Account and following the steps, or you can copy over the client’s existing authorisation for self assessment from your HMRC online services for agents account to the ASA.

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