Recognising that companies need this information to complete pension payroll moves, HMRC has shared an early version of the amended guidance, stressing that the guidance is not final but ‘any changes will be minor and will not affect the substance’. This guidance is set out in the ‘less common circumstances’ section of the gov.uk pensions guide.

For companies moving pension recipients from one payroll to another, HMRC has confirmed that administrators will need a new PAYE reference to:

• transfer the payroll records to the new employer reference;
• will have to send a Full Payment Submission (FPS) under the old employer reference with leaving details, including the year to date pay and tax figures. A P45 should not be produced;
• send an FPS under the new employer reference restarting the year to date figures from zero and put the full starting details for each recipient on the FPS for the new reference. Also include the start date for the new payroll, annual amount of their pension; and occupational pension indicator.
• leave the occupational pension bereavement field on the FPS blank, unless the pension is being paid to a dependent who has been bereaved since the pension recipient joined the new payroll;
• work out and deduct PAYE tax from any payments made to the transferred pension recipients from the date they moved payrolls;
• if operating a cumulative tax code use the pay and tax details from the old employer reference.

It is important to submit the last FPS from the old reference before submitting the first FPS for the new reference. If there is a problem with this, contact HMRC’s employer helpline.

There are also specific rules for employees who have more than one pension under the existing PAYE scheme. In these instances, employers must contact the HMRC employer helpline at least two months before the scheduled transfer.

HMRC said it would ‘contact [employers] within 15 working days for further information about these cases. We’ll review these cases and, if appropriate, we’ll issue revised tax codes after the transfer has taken place’.

For those with dual or multiple schemes, employers must notify HMRC if any members are being moved and they:

• receive more than one pension under the existing PAYE scheme which are paid under separate payroll IDs and this arrangement continues under the new PAYE scheme;
• have multiple pensions paid under one payroll ID at the old reference but will be paid under separate payroll IDs at the new reference;
• have a suffix T code, including 0T and NT; and
• are paid in advance and the month 12 FPS shows an end date which falls in the following tax year. For example, a pay date of 01/04 and an end date of 30/04.

HMRC said it will confirm when the guidance is finalised in a future issue of its regular Pension Schemes newsletters.

To update details on complex cases, contact the HMRC Employer Helpline