Last updated: 30/03/2015
See also: Change of address | Gateway to hell | Companies House: hang your head in shame | How to deliver customer service and save money (not) | How to get people to use online services (not) | Danger signs | Better public services through Call Centres | Global village
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Royal Bank of Scotland recently sent me a letter headed Action required to provide documentation. It related to the US Government's concerns that I might be trying to avoid tax due in the USA. It asked for my FATCA status and (possibly) my GIIN. I say 'possibly' because I do not know whether I am a (Sponsored) Direct Reporting NFFE. The letter gave me two suggestions of how to find out - talk to my tax advisor or phone a hell line. I thought I would start with my advisor. After all, I do pay him. But he couldn't help because he had never seen a FACTA Declaration and certainly could not provide me with any advice because he had not been trained to tell me how to fill out the form.
Over to the hell line. Very friendly RBS employee who gets queries like mine a couple of times a day. Don't worry, he said. What did I need to know?
What are active NFFEs and what are passive NFFEs, I asked.
I am sorry, I cannot tell you that because I am not licensed to give tax advice.
That is odd, I said. Your letter suggested I seek independent financial advice, but my advisor didn't know anything about FATCA either.
I'm not surprised. This is a new regulation and it only applies to accounts set up after June 2014. But I can tell you how to find out. Go to GOV.UK and type " Automatic Exchange of Information Agreements " into the search box.
Why didn't I think of that!
Then go to page 17 where you will find the definitions.
An Active NFFE is defined as any NFFE that meets ONE of the following criteria:
STOP JUST THERE. Where in the 181 pages of this guidance note do I find out what "passive" means apart from "not active"?
That is on about page 22.
And what happens if I just choose a random option for the form or simply don't fill in the form?
We forward the form to the UK tax authorities or tell them that the form has not been completed.
And your letter says that if I don't fill in the form you will assume that I am a tax resident of the USA. What are the implications of that?
I can't tell you that.
Thanks to Ernst & Young who issued an advisory note on the web explaining that there would be a 30% withholding tax on "US source FDAP" by which they mean "passive income" like dividends, interest, rents and royalties and explicitly excluding revenues from trade with an entity in the USA.
So no big deal for me, then. And for you? In the unlikely event that more than half of your income comes from US-sourced dividends, interest and so on then you will be taxed at source. Why could they have not simply said that? Or simply looked at the account transactions and work it out for themselves?
Time for a check-up on the gateway to hell. I wanted to notify an upcoming change of address. After a false start (see box below) I thought I had cracked it. Read on.
I like "quick and easy", "safe and secure", "convenient", which is what the "Tell HMRC about a change of name or address by email" feature offers:
If your circumstances have changed and you've changed address or your name you can let HM Revenue & Customs (HMRC) know using their email service. This method is:
If you're registered for Self Assessment Online, you're leaving the UK, you would like to change your business name or address or you have previously been given specific instructions about contacting HMRC you'll need to use a different method.
OK, just ignore the last bit. It took me to the pages about VAT. Actually, that would have been more useful than what got thrown at me next:
What committee of HMRC project managers dreamed that one up?
Use the government gateway - login, select the service you want and then . . . Login again
Except for the ECSL.
Today I got routed to a screen telling me I was filling in a form because I'd forgotten my password and wouldn't let me submit it because the 'Branch ID' (I am a sole trader) was in the wrong format. But of course I couldn't fix that because it wouldn't let me in to find out what it was.
After three tries it locked me out and told me to contact the helpdesk. It didn't tell me HOW to contact the helpdesk, just told me to go away. So I found the four month old email notifying me of my activation code to ECSL, which of course was read-only (do not reply). There was what looked like a very useful link that promised to tell me all about the ECSL. But instead, it took me to the international trade home page of BusinessLink.
So I did what every IT-literate person does in this age of joined up government. Went to the HMRC home page and drilled down till I found online VAT services login. Used the gateway login, no problem. Except that I forgot to bookmark the page. Again.
If you want to find out how to set up a new company, you would probably start at the Companies House website, wouldn't you? Well, Monday to Saturday (7am to midnight) you would. BERR presumably think that at other times you should be asleep or something, because on Sundays and in the early hours, the home page says: Access to the service is closed
Except it isn't! There's a link on the page just under that statement which invites feedback. Thinking I could at least let off some steam, I followed the link, submitted a few rude comments and was surprised to arrive at a screen saying welcome to the Companies House website. Not everything they advertised worked, but most of the links were active.
Right first time? Eliminating waste? Try this for logic. I was thinking of moving to the West Country a while ago and the first stage was giving up the office in Teddington where I'd been based for 17 years. I wrote a nice letter to the Council Revs & Bens team, telling them I would be surrendering the lease on March 31st.
First thing I get is a phone call (costing, what, £1.50 to the Council - a back office worker, not a contact centre). Thank you for your letter. We'll put it in the pending file and when we get to the date it mentions, we'll process it.
Then I get a business rates notification for the period starting April 1st. No overlap at all. Nor any cross-reference with the person who phoned me, obviously. Cost - probably another 50p or so.
At least I get the reminder that I should be cancelling my Direct Debit Just In Case - they might forget about my letter, mightn't they?
So I get a letter saying "We notice that you've cancelled your direct debit. It may be that you're moving, in which case please send us the following information:" - followed by an accurate description of the contents of the letter I’d already sent them, that they had on file, which they were not going to read until after I’d moved. Cost - let’s be charitable and call it another 50p.
You’ve guessed. I have to phone them (another £1.50) to tell them about the letter I sent them and explain that, no, I won’t be sending another one.
But we have to do it this way - it is a standard procedure.
Postscript: a bundle of specially printed paying-in slips for me to not use when I don't pay the council tax that I don't owe.
Inland revenue online filing guide (presciently identified as "BS" 09/03) points you to the web-site, which encourages you (as an employer) to register for online PAYE filing. Except that when you follow the instructions it rejects you and the form expires and you can't do anything except … call the help line (see article on Call Centres, below)!
First time I got referred to another helpline, or rather to a number that didn't work. Second time around, the agent transferred me to a third agent. I still don't know what the correct number is.
The third agent took my name, address, PAYE reference, Accounts Office reference (which is on the yellow paying-in book, as the web-site said and consists of three digits, two alphas, six digits) and then said "What you have to do is add two zeroes between the alphas and the last six digits of the accounts office reference."
I see, said I - so following the instructions on screen doesn't work. Is this being fixed or am I the first person to have this problem?
"You are not the first."
So, I asked - how long has this problem been known about?
"I'm not able to disclose that information."
OK, let's put it this way - do you often get calls from people who can't register?
"I'm not able to disclose that information either."
So, there's a problem with …
"I didn't say there is a problem. There isn't a problem. The system is fine. The PAYE people put the extra digits in when they entered your reference code."
On a related subject:
"Government, political and public services websites are relatively large, approximately equal in size with the average UK FTSE 100 corporate website. The average UK corporate website when tested by B2W had 85 errors; the government average was 600 - nearly 7 times as many. The number of site warnings was also significantly higher, and (the) server was slower." - Business2www report (Website tests and ranking for the Major UK Central Govt. Websites, April 2003).
Public Finance magazine on October 17th published 18 signs that help indicate whether your project is threatened. The article suggests that if any four of these apply then failure is virtually certain.
Thanks to Roger Wilson for the reminder!
(from the House of Commons Public Accounts Committee, 5 June 2003)
Departments need to be more adept at estimating the likely volume and incidence of calls to enable them to manage the demand in the most cost effective way.
Read the detailed report for more on setting realistic performance targets and what constitutes good (or even excellent) service! (http://www.publications.parliament.uk/pa
Thank you to Dave Charles of Devon County Council for finding the reference.
What the world would look like if it were reduced to a village of 1,000 people?
- taken from an EC newsletter of 1999. Thanks to Srba Cvetkovic of Vodaphone for reminding me of this one!