A new client is a contractor, is registered for CIS, has paid the tax over to HMRC. As I understand it, and from HMRC's website, "At the end of the tax year, the company should show its CIS deductions on the P35 Employer Annual Return. The P35 Employer Annual Return must be completed even if the company had no employees during the tax year. In these circumstances, the P35 Employer Annual Return must be submitted as a complete return with no P14s."
The problem is, he's not registered as an Employer and so doesn't have a PAYE reference number, so how can he submit a P350?
He has an Accounts Office reference number which he uses to pay HMRC what he has collected.
Anybody come across this ? - tried ringing HMRC but have been on hold since time immemorial.
My instinct would be to check that the accounts office reference is for a PAYE Scheme. If it is AND no PAYE Reference has been issued then that would be good grounds for a successful appeal against late filing penalties. All the better if you can show that you've requested the PAYE Ref. before 19th May.