Omni – Pension Schemes Online – APSS301
The returns can be accessed via ‘Reports, Pension Schemes Online’, as long as you have the user-rights to prepare the returns.
The main return for SSASs is the ‘Registered Pension Scheme Return for Occupational Pension Schemes (APSS301)’.
The APSS301 is only needed if the SSAS receives a notice from HMRC. However, it appears that notices have been issued to all SSASs. The return has to be submitted, if requested, even if it is a ‘nil’ return.
If a report is needed for the tax year ended 5th April 2007, it must be submitted by 31st January 2008. The deadline is earlier if the scheme has wound up.
To be able to submit the return from Omni, all of the data needs to be entered first. It is recommended that the Accounting Data function (on the Reports menu) is run for the year to 5th April. If all of the information for the accounts is in Omni then most of the data for the scheme return should be available.
It is recommended that the return and the accompanying notes are read in detail.
The scheme administrator needs to be selected on the Trustee screen. The return can be prepared for any administrator but it can only be submitted via Omni if the professional trustee is the Scheme Administrator. The User ID and password are the same as used for normally logging to the Pension Schemes Online website (these are stored under ‘Settings’).
You should decide whether all of the necessary data is stored in the main database or additional details on assets needs to be entered. Details on income from assets can be entered specifically for the return – full details are in Asset Data.
To prepare the return, enter the Online Reporting program and select ‘Pension Scheme Return, New/Amend Return’. This displays a list of any previous drafts or any submitted returns. From here, you can click the New button to prepare a new return or select a draft so that you can view it or submit it.
Once the return is prepared you can view the return or print it for checking.
You cannot amend the return itself. If the return is not correct then you should amend the main database and/or the return asset data to reflect the correct data and re-run.
When you have checked the return you can retrieve the draft and then complete the declarations. Once the declarations have been completed, the ‘Prepare for Submission’ button is enabled. On the next screen you click submit (none of the details can be edited). Omni then asks if you wish to proceed. If you confirm, then Omni will communicate with HMRC’s database and obtain a receipt.
The return is stored and the receipt is stored at the top of the return, including an IR mark, which identifies the submission. This receipt simply confirms that the return was received by HMRC in a valid structure – it does not confirm that the data has been agreed by HMRC.
Once you have submitted the return, if you find that the data was incorrect and you need to amend the return, you can prepare and submit another return in the same way.
If the HMRC service is not available, perhaps due to upgrades, then HMRC will accept the return but not send a receipt. The receipt will be shown as a message when the administrator next logs on to the website. The receipt (IRmark) will be supplied but then you will need to update Omni’s record of the return and copy and paste the IRmark. This is cumbersome and so we recommend that you avoid submitting returns when the HMRC service is not available.
The following issues are worth considering:
1. The return requires you to distinguish between assets that have been acquired from connected parties at any time in the past and those that were bought on the open market. As a result, you will need to distinguish between rent received from any tenant where the property was bought from a connected party (Section 8.6) and rent received from any tenant (connected or not) where the property was acquired at arms-length (Section 12.8). Conventional accounts will not generally show that information.
2. Section 12 refers to all other assets not covered in previous questions, and so details of holdings, purchase and sales of quoted equities, gilts, unit trusts etc need to be shown. This can involve a lot of work.
3. Interest on bank overdrafts and bank loans should not be deducted from bank interest received.
4. HMRC have indicated that the information should not be approximated e.g. some SSAS administrators will set up a 5 year loan with equal repayments and assume that the interest content in each payment in a loan year is constant – HMRC have suggested that the accurate amount of interest for each payment in the parts of the loan year which fall in the tax year need to be recorded precisely.
5. In 2009, HMRC issued notes on how to amend an APSS301 return. These conflicted with previous less detailed notes and required extra amounts to be included in box 4.7 (repayments of borrowing and loanbacks, including capital and interest). Omni was updated in 2010.