Paper CGT returns for reporting UK property disposals

1 Mar 2023

Following our letter to HMRC last year requesting that CGT on UK Property (PPDCGT) forms were made available to download, we are delighted to report that HMRC have today provided direct access to the PPDCGT forms on GOV.UK for disposals in 2022/23 and 2023/24 where the normal digital process is not suitable. These downloadable forms are not available for disposals made in 2020/21 or 2021/22 which have not yet been reported and tax not paid - in that instance HMRC must be contacted for a paper form as usual.

This means that agents and taxpayers who are unable to use the online service to report relevant property disposals, will be able to download a paper version of the form. Until now, it has been necessary to ring HMRC to request a paper form. This has caused problems for taxpayers and agents firstly because of the wait times on HMRC’s helplines, and secondly because of the time taken for forms to arrive via post.

Background

UK residents have been required to report disposals of a residential property on which Capital Gains Tax (CGT) is payable since April 2020. The rules require UK residents to calculate, report and pay the estimated CGT within 60 days of the completion of the sale.

Similar, but broader, rules apply to non-UK residents. Non-UK residents must report disposals of any UK land or property, including that held indirectly in property rich entities within 60 days of the sale completing, whether or not a gain is made.

When should paper forms be used

Although we are pleased that agents will now be able to download the required forms, it should be noted that the online service is still HMRC’s preferred route for reporting. As noted in HMRC’s letter regarding the availability of the paper form:

“HMRC consider that the existing online service is the most secure and efficient way to notify HMRC of a residential property disposal and pay the CGT that is due. Consequently, the form is being made available to download on a trial basis. This trial will allow us to make sure that the service is properly designed and to ensure that customers are only using the paper form when they can’t use the existing digital route.”

In addition, reporting via the online service means agents can more easily make amendments to returns, see whether clients have paid the tax, and avoid processing delays including the time taken for HMRC to issue payment instructions.

According to HMRC’s CGT manuals, the following taxpayers are permitted to use a paper form.

  • Digitally excluded taxpayers or those unable to pass HMRC’s online verification process
  • An agent who has been engaged only to deal with a return
  • A personal representative who wants to authorise a different agent to deal with the deceased estate to the one who deals with their individual tax affairs
  • A personal representative who wants to amend a return which has already been sent online
  • A Capacitor (such as Power of Attorney) who wants to authorise an agent to file, the UK property return
  • A Capacitor who wants to amend a return which has already been sent online
  • A corporate trustee
  • A non-resident trustee who needs to report the disposal of UK property or land but doesn’t have any non-resident Capital Gains Tax liability to pay
  • A secure or Public Department 1 customer who doesn’t file returns online with HMRC.
  • A person that has already submitted a Self Assessment return prior to the UK property return.