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Possible individual extensions to digital links deadline for MTD

17 October 2019      Amanda Darley, Head of Operations and Engagement

A couple of months ago BUFDG was involved in confidential discussions with HMRC around how some businesses/universities may struggle to meet the deadline for the end of the soft landing period for implementing digital links for Making Tax Digital. In particular we referred to universities who may be going through a new finance system implementation or upgrade or who may have a large number of systems to link.

HMRC has now contacted us to draw attention to a new process to allow taxpayers to apply for extra time, if they need it, to fully comply with the digital links requirements. A new version of Notice 700/22: Making Tax Digital for VAT has been published today, detailing this new process at section 4.2.1.3.

This sets out the following criteria:

'To be considered for a specific direction, you will need to:

  • make a formal application to HMRC as soon as possible for an extension and by no later than the end of your soft landing period
  • explain why it is unachievable and not reasonable for you to have digital links in place by the MTD VAT digital links mandation date (in April 2020 or October 2020, for businesses mandated to join MTD in 2019) for example, why does commercially available software not meet the digital link requirement for your business?
  • submit details of the systems that are unable to be digitally linked (provide a current map of your existing VAT systems, highlighting the exact areas that cannot be digitally linked)
  • provide a clear explanation and timetable for when and how you will become fully MTD compliant (ordinarily no later than one year from the end of their soft landing period)
  • state the controls you will put in place to ensure any manually transferred data is moved accurately and without error'

There is more detail in section 4.2.1.3 of Notice 700/22 and if you feel you are struggling to meet the deadline for digital links we would encourage you to read it. Please note that cost alone is not a sufficient reason for an extension of time.

For more information about HMRC's communication with BUFDG on this, please see this discussion post.



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