No more company annual return

[TheCyclingProgrammer]

Has anybody received notification from either Companies House or their accountant about these new changes effective 6 April (PSCs) and June (confirmation statement)? The annual return is now replaced by an "annual confirmation statement" and there's also a requirement to keep a register of PSCs (persons of significant control):

Filing: overview of the move from annual return to confirmation statement - Articles - Olswang LLP
https://www.gov.uk/government/public...y-partnerships

First I heard about it was a few days ago.

[jaffab]

Yep - I got mine by email. Accountant had warned me it was on its way (had just done the yearly accounts sign off) - there are lots more changes on the way... simplification of accounts return (gone from the 7 or 8 current pages down to 2 or 3), an 'interest in property' form (we have to start completing this in the next 12-18 months, used for property owned/rented/used by a company) etc.

This one (according my accountant) is another in the long line of tax avoidance measures - so that they can work out who is really a PSC, who is a director, and therefore work out if there are gaps in terms of NI, PAYE, dividends etc.

Hey, its just easier to bash the small guy than to risk offending the corporations who pay money to the political parties.

[TheCyclingProgrammer]

So my accountant just got back to me. He said the new confirmation statement is largely the same thing although they'll know how different is once they've done their first one in June.

He said for small businesses and freelancers/contractors it should be pretty much business as usual. Likewise the PSC register (people of significant control, not "personal service company" ) is just another statutory register to be kept along with all the usual ones (lists of shareholders, directors etc.) that needs to be kept but is mainly an issue for bigger businesses with multiple shareholders.

[Jessica@WhiteFieldTax]

Information on this has been quite patchy, and its still difficult to get precise detail from Companies House.

It seems as if the Confirmation Statement is all but the Annual Return in another guise, although for those who value privacy over extra work (politicians families?!) you can opt to keep the register of PSCs yourself and not publicly file them, but then you have to have access arrangements.

Major change is the date cycle is now "anywhen" rather than every "12 months" - not clear how transition will work

Not clear how Companies House filing fee will change. Up? Down? The same?

There are criminal penalties for not complying, but will they be used in practice?

https://www.gov.uk/government/news/t...ming#checkconf

https://www.gov.uk/government/upload...fact-sheet.pdf

We briefed clients with the Budget 2016

The Persons with Significant Control regime came in earlier this year. It requires companies to ascertain who controls their shares and keep a register. Of course in many cases – most – it’s the shareholder but if there is a nominee or trustee type issue then the person with ultimate control need to be registered. The register can be kept privately by the company, and subject to inspection, or most companies are expected to let Companies House hold it for them.

Of most interest is that this means a change to the Annual Return procedure at Companies House from summer this year onwards. Watch this space, all we know at present is:

Confirmation statement

A requirement to ‘check and confirm’ the company information by filing a ‘confirmation statement’, and notify changes if necessary at least once every 12 months. This will replace the current obligation to file an annual return.

[Maslins]

Yup, my understanding is that for our typical client it'll basically just be a rebranding of the annual return.

I had thought that the primary motive would be transparency for the more convoluted group structures. Eg where A Ltd is jointly owned by B Ltd and C LLP, and B Ltd's shareholders include international firm D GMBH and E Inc etc etc. A bit like the ultimate controlling party note, I thought it was just trying to give a clear indication for A Ltd of who's actually in control of it/beneficiary of its profits.

Interesting to hear you can opt out of it though...and baffling. Defeats the point IMHO.

[TheCyclingProgrammer]

One other thing that my accountant mentioned in passing is that I could keep my existing company register online - no need to keep the big folder of stuff I first got from Nixon Williams many years ago. Can I get rid of this and if so is there an "official" place to upload it to or can I just keep digital copies somewhere?

[Jessica@WhiteFieldTax]

One other thing that my accountant mentioned in passing is that I could keep my existing company register online - no need to keep the big folder of stuff I first got from Nixon Williams many years ago. Can I get rid of this and if so is there an "official" place to upload it to or can I just keep digital copies somewhere?

I would suggest Dropbox...

Which is of course hosted on Amazon Web Services, the same as Companies House own database, meaning any debate about "safe harbour" etc is hypothetical.

There may, somewhere, be a rule about keeping paper copies of registers, but that will only be because no one has updated the legislation. There is no expectation for paper anything these days.

[TheCyclingProgrammer]

I would suggest Dropbox...

Which is of course hosted on Amazon Web Services, the same as Companies House own database, meaning any debate about "safe harbour" etc is hypothetical.

There may, somewhere, be a rule about keeping paper copies of registers, but that will only be because no one has updated the legislation. There is no expectation for paper anything these days.

Well that's good news, as I've been lugging that damn folder about with me for 7 years.

Dropbox is fine, I already keep most of my company records in digital form apart from the handful of things that need to be kept in their original form.