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					                 BOURNEMOUTH
                       &
                 POOLE BRANCH
                 PAYE YEAR END
                   MIKE EVANS
                 MY CONSULTANCY
                  23 February 2011




MY CONSULTANCY
          INTRODUCTION

•   Preparing for Payroll Year End 2010/11
•   Online Registration and Filing
•   PAYE and NIC Pointers and Changes
•   Fuel Reimbursement for Business Travel




                                             2
MY CONSULTANCY
          PREPARING FOR PAYROLL YEAR END

 The purpose of making the EOY return is to:
 • Summarise the payments & statutory deductions made during
   the tax year (P35)
 • To balance the amounts of income tax, National Insurance
   Contributions and Student Loan Deductions due to HMRC
   against the actual payments made during the year
 • The employer takes responsibility for the payroll, even if it is
   processed via a bureau
 • The return is supported by details of each employees‟ or
   pensioners‟ payments & deductions (P14s)

                                                              3
MY CONSULTANCY
           PREPARING FOR PAYROLL YEAR END

• Employers are statutorily required to make an end of
  year return to HMRC
• Within 44 days of the tax year end
• By Thursday 19th May 2011 for 2010/11
• Extra Statutory Concession B46
   •   Extended this time limit by 7 days!
   •   Wider application than PAYE Returns
   •   Extension intended to cover postal delays
   •   Online filing means it is no longer required
• ESC B46 not effective after 31 March 2011
                                                      4
MY CONSULTANCY
          PREPARING FOR PAYROLL YEAR END

• All employers must now file their P14s & P35 online
   • There are a few exceptions
• Failure to do so will incur a penalty
• Only the P35 & P14s must be filed Online for each
  PAYE reference number
• One P35 per PAYE reference
• Employers can send the P38A Online if they want to
• Alternatively download P38A and post to HMRC
• Same 19 May 2011 deadline
                                                   5
MY CONSULTANCY
              HOW MUST WE FILE THE
           PAYROLL YEAR END RETURNS?
• The Exceptions to online filing are:
   • Domestic employers using the simplified deductions scheme
       • Not if incentive payments claimed previously
   • Care and support employers – that is people who employ
     someone to provide care for them or a member of their
     family at home and returns not submitted by an Agent
   • Certain religious groups
       • Not if incentive payments claimed previously
• Any employer who thinks they are exempt from online
  filing needs to contact their HMRC office
                                                         6
MY CONSULTANCY
          PREPARING FOR PAYROLL YEAR END


 • Filing online means via a telephone line (not by
   email) using either Internet or EDI, or
 • A combination of both
 • For example the payroll bureau submits the P14s
   via EDI and
 • The employer submits the P35 via the Internet
 • Does the employer know that?


                                                  7
MY CONSULTANCY
          PREPARING FOR PAYROLL YEAR END


•   A full return must consist of one P35 and
•   At least one valid P14
•   The return must meet the published Quality Standard
•   Does your payroll or your Client‟s payroll meet the QS
•   Does it perform checks during the tax year?
•   Don‟t send a paper P35 as well if you file online
•   No paper P35 will be sent by HMRC


                                                     8
MY CONSULTANCY
          REGISTERING FOR ONLINE FILING

• Register and enrol with HMRC‟s Online Services by logging on
  to the HMRC website home page (www.hmrc.gov.uk/index.htm)
   • Click on Register (new users) in the Do it online box
   • Click on Organisation and tick the PAYE for employers box
   • You will need to have ready:
       • Employers PAYE reference e.g. 951/A12345
       • Accounts Office reference e.g. 951/PR00056789
   • There are six steps to registration leading to:
       • Creation of a password and noting your User ID
• The final step will be receipt of the activation pin

                                                        9
MY CONSULTANCY
     REGISTERING FOR ONLINE FILING




                                 10
MY CONSULTANCY
                 11
MY CONSULTANCY
          ONLINE REGISTRATION




                                12
MY CONSULTANCY
          ONLINE REGISTRATION




                                13
MY CONSULTANCY
          ONLINE REGISTRATION




                                14
MY CONSULTANCY
          ONLINE REGISTRATION




                                15
MY CONSULTANCY
          ONLINE REGISTRATION




                                16
MY CONSULTANCY
          ONLINE REGISTRATION




                                17
MY CONSULTANCY
          ONLINE REGISTRATION




                                18
MY CONSULTANCY
           ONLINE REGISTRATION

• The Activation Pin should be used immediately to
  activate the PAYE online registration
• Then, having completed the 6 steps to registration, or
  where we are an existing user, we can log on at any
  time to file our PAYE Returns
• Enter the User ID and online password
• The „At a glance‟ page shows our options



                                                   19
MY CONSULTANCY
            PAYE ONLINE FILING




                                 20
MY CONSULTANCY
          PAYE ONLINE FILING

• Before we think about filing the PAYE Returns
• Check for any notices from HMRC
• This we also do from the „At a glance page‟
   • See next slide
• We can ask HMRC to send us email notifications
• Tell HMRC what email address to use
   • Next but one slide



                                                   21
MY CONSULTANCY
          HMRC PAYE NOTICES




                              22
MY CONSULTANCY
          EMAIL NOTIFICATIONS




                                23
MY CONSULTANCY
          PAYE ONLINE FILING

• When we first start using online filing we may have to
  create our employee list
• Subsequently adding new employees to the list when
  they join the company and
• Using the online facility to send joiner and leaver
  forms to HMRC




                                                    24
MY CONSULTANCY
          PAYE ONLINE FILING




                               25
MY CONSULTANCY
                  ONLINE FILING OF IN-YEAR
                       PAYE FORMS
• Employers with 50 or more employees must file PAYE starter
  and leaver forms online
• The PAYE forms that must now be filed online are:
   •   P45 Part 1 when an employee leaves
   •   P45 Part 3 when an employee starts
   •   P46 when a new employee starts without providing a P45
   •   P46 (Pen) for details of a new pension or annuity that the employer starts to pay
   •   P46 (Expat) for employees „seconded‟ to work in the UK
• HMRC has been „totting up‟ the paper forms submitted in error
  and will be issuing penalty notices to defaulting employers


                                                                                26
MY CONSULTANCY
             ONLINE FILING OF IN-YEAR
                  PAYE FORMS
 • All employers must file their PAYE starter and
   leaver forms from 6 April 2011
 • Not long now!
 • Why not start now?




                                                    27
MY CONSULTANCY
ONLINE FILING OF IN-YEAR PAYE FORMS




                               28
MY CONSULTANCY
                 29
MY CONSULTANCY
          ONLINE LEAVERS DETAILS




                                   30
MY CONSULTANCY
          ONLINE LEAVERS DETAILS




                                   31
MY CONSULTANCY
                 STARTER/LEAVER FORMS
                      SUBMISSION




                                        32
MY CONSULTANCY
          STARTER P46 STATEMENTS




                                   33
MY CONSULTANCY
                 34
MY CONSULTANCY
                 35
MY CONSULTANCY
          ONLINE FILING OF PAYE RETURNS

 Sending the Return
 • Quick response times for Internet acceptance & rejection
   messages
    • Normally one minute
 • Large files may take longer
 • Filing via EDI takes much longer
 • If a response is not received contact
    • Online Helpdesk or EDI Account manager
 • Do not re-send until you know the first submission has not
   been received
 • Keep a copy of the acceptance message
                                                           36
MY CONSULTANCY
          ONLINE FILING OF PAYE RETURNS

Sending the Return
• Always send the P35 last
• Lets you amend P14s already sent before the return is
  complete
• No further amendments can be made after the return has
  been accepted
• Corrections will have to be made by writing to the tax office
  to explain



                                                             37
MY CONSULTANCY
          ONLINE FILING OF PAYE RETURNS

Sending the Return in Parts
• Perhaps with the Employer has Branches around the UK
• Each part must have a unique identifier
• Using the same unique identifier for each part will result in
  each part overwriting the other
• You must confirm how many parts you have sent on the P35
   • Not how many P14s you have sent
• The number of parts excludes the P35



                                                            38
MY CONSULTANCY
          PREPARING FOR PAYROLL YEAR END


 P60 (Summary of Annual Pay and Tax Details)
 • Employers will have the option to provide employees with
   P60 information in paper or electronic format
 • The change comes into effect for the current tax year
   2010/2011 onwards
 • The first P60 that can be provided electronically will be that
   for the year ending 5 April 2011
 • The information recorded on the form P60 is not changing
 • HMRC publication RD1 (Substitute forms P60) has been
   updated

                                                              39
MY CONSULTANCY
          PREPARING FOR PAYROLL YEAR END

  • Preparation for Payroll Year End starts in February
  • Time to make some checks
  • Are there any non-standard tax codes operating
      •   NT
      •   BR
      •   0T
      •   DO
      •   D1
  • Are there Notices of Coding to support the codes in
    use?
                                                   40
MY CONSULTANCY
          PREPARING FOR PAYROLL YEAR END

NATIONAL INSURANCE CHECKS
• Check that the NICs Category letters are correct
• Category A is the most common
• Category X means NO NICs
   • BOTH Employee and Employer
• Category X will be the default
   • If no NICs, and
   • No NIC entries
• Do not use Category X if earnings reach LEL in any week or
  month
                                                         41
MY CONSULTANCY
            NIC CATEGORY LETTERS

                      NOT               CONTRACTED      CONTRACTED OUT
    RATE         CONTRACTED OUT         OUT SALARY      MONEY PURCHASE
                                       RELATED (COSR)       (COMP)
Standard rate            A                   D                F

Reduced rate              B                  E                G
                 Married women and
                 widows reduced rate

Employer Only            C
                  Over pension age

Employee                 J                   L                S
Deferment
CA2700
                                                                  42
MY CONSULTANCY
          PREPARING FOR PAYROLL YEAR END

NATIONAL INSURANCE CHECKS
• Is there evidence to justify any lower rates of NICs deducted?
   • Age Exception                  CA4140
   • Married woman lower rate CA4139/CF383
   • Deferment                      CA2700
• Recalculate Director‟s NICs at year end if the Annual Earnings
  Period was not used
• Have any employee loans been written off where Class 1 NICs
  are due?


                                                          43
MY CONSULTANCY
          PAYE POINTERS - CASUAL LABOUR

• Minimum recording requirement for PAYE
• Employers must keep a record of the name, address
  & wages paid to the worker in each pay period
• PAYE threshold of £125 per week or £540 monthly
• Reduced to just £1 if no P45 provided, or
    • P46 not completed, or
    • Worker ticks Box C on P46, or
    • Has another job or a State or occupational Pension


                                                           44
MY CONSULTANCY
          PAYE POINTERS - CASUAL LABOUR

 • There does need to be adequate controls
 • It is NOT acceptable to pay casual labour through
   petty cash without keeping the required records
 • Would your business employ strangers?
 • Are P38A Employer Supplementary Returns being
   submitted annually to HMRC?




                                                  45
MY CONSULTANCY
         PAYE POINTERS - CIS LABOUR

• Casual labour in the Construction Industry is a different issue
• Contractors often confuse casual labour and self-employed
  subcontractors, but
• Contractors are required to check their workers employment
  status and must confirm every month that no individuals are
  employed under a contract of employment
• Contractors must verify all new subcontractors
• Before making the first payment to the new subcontractor
• Contractors that fail to operate PAYE on employed workers
• May lose their subcontractor Gross Payment Status

                                                            46
MY CONSULTANCY
           PAYE/NIC POINTERS – EMPLOYMENT
                        STATUS

 Employment Status?
    • Difficult issue and we have already considered casual
      labour and confusion with self-employment
    • Useful end of year check is to look at any „off payroll‟
      payments to individuals and check the contracts,
      engagement letter and/or Terms and Conditions
    • If in doubt use HMRC‟s Employment Status Indicator tool
 • Do we need to include anyone on the payroll?
 • Remember who will pick up the bill!

                                                          47
MY CONSULTANCY
           PAYE/NIC POINTERS – EMPLOYMENT
                        STATUS

Example – Consultant etc. paid £600 per week (2010/11)
• Class 2 @ £2.40 x 52                = £124.80
• Class 4 @ 8% (5,715 - 31,200)       = £2,038.80
• Total Class 2 & 4                   = £2,163.60
• Class 1 @ 23.8%                     = £6,064.24
• Loss to NI Fund                     = £3,900.64 (64%)
• The Employer might end up paying this to HMRC!
• And the PAYE NOT deducted (BR) = £6,240.00



                                                          48
MY CONSULTANCY
           PAYE/NIC POINTERS – EMPLOYMENT
                        STATUS

• Employers too often confuse casual labour with
  self-employment
• Casual workers are more likely to be employees,
  but they might be self-employed
    • Repairing a leak or a light – self-employed?
    • Regular maintenance work – employed?
    • Park Parade Hotel or Demibourne?
• The casuals in the former Trust House Forte Hotels
  were found not to be employed earners

                                                     49
MY CONSULTANCY
         PAYE POINTERS - STUDENTS

• The P38(S) procedure allows an employer to pay a student
  employee without deducting income tax
• It does not set aside PAYE procedures
• Only applies to students working in the school holidays
   • P46 procedure applies otherwise
• Student employees must sign a declaration to confirm that:
   • S/he is a student and will be until 5th April, and
   • The „total earnings‟ will not exceed £6,475 (2010/2011)
• Code NT applied and no income tax deducted unless the
  earnings exceed the personal allowance limit
                                                         50
MY CONSULTANCY
             PAYE POINTERS – TERMINATION
                      PAYMENTS

 • Untaxed Termination Payments?
 • Risky to assume that termination payments will always attract
   the £30,000 income tax exemption and/or
    • Are exempt/not earnings for NICs
 • Compensation or damages should be exempt
    • Up to £30,000 for tax and No NICs liability
 • Statutory Redundancy payments are exempt
 • Payments in lieu of notice and Ex-gratia payments are a
   potential “minefield”
 • Do you need to check that PAYE has been operated on all
   contractual payments?
                                                           51
MY CONSULTANCY
          PAYE POINTERS

• Other payments that often result in payments of
  income tax, NICs, interest and penalties to HMRC
   • Round sum allowances/per-diems not covered by a P11D
     dispensation?
   • Non-receipted expenses?
   • Mobile phone top-ups?
   • Oyster card top-ups?
   • Home to work travel reimbursement
   • Other personal expenses

                                                      52
MY CONSULTANCY
          PERSONAL ALLOWANCE CHANGES

• Personal Allowances to be increased in 2011/12
   • Increased by £1,000 to £7,475 for people under 65
   • Increased to £9,940 age 65-74; to £10,090 age 75 and over
   • 500,000 less people paying income tax!
• Basic rate band of £ £37,400 to be reduced to £35,000
• Stops higher rate taxpayers benefitting from the
  increase in personal allowances
• 750,000 more people to become higher rate taxpayers
• More increases in allowances & reductions in BR band
  likely to come in future years
                                                         53
MY CONSULTANCY
          PERSONAL ALLOWANCES CHANGES

• Personal Allowances reduced this tax year by £1 for every £2
  above the income limit of £100,000
• This applies regardless of the individual‟s age
• HMRC notifies employers of tax code changes on form P9(T)
  or an electronic equivalent
• HMRC estimates earnings for this purpose
• Employers do not need to do anything
• We should check the HMRC estimates



                                                          54
MY CONSULTANCY
          NATIONAL INSURANCE CHANGES

 National Insurance Contributions from 6 April 2011:
 • Employees will pay 12% (11%) on earnings between the
   Primary threshold and the Upper Earnings Limit; and
 • Increase to 2% (1%) on earnings above the UEL
 • Employers will pay 13.8% (12.8%) on all earnings above
   the Secondary threshold
 • The Secondary threshold will rise by £21 a week
   above indexation
 • Class 4 NIC rates will increase to 9% (8%) and 2% (1%)


                                                        55
MY CONSULTANCY
           NATIONAL INSURANCE CHANGES

Weekly Limits (monthly in brackets)         2010/2011   2011/2012
Lower earnings limit, primary Class 1          97       102 (442)
Upper earnings limit, primary Class 1          844      817 (3,540)
Upper accrual point                            770      770 (3,337)
Primary threshold                              110      139 (602)
Secondary threshold                            110      136 (589)
Employees‟ primary Class 1 rate               11%          12%
Employees‟ primary Class 1 rate above UEL      1%          2%
Class 1A and Class 1B rate                    12.8%       13.8%
Married women‟s reduced rate                  4.85%       5.58%
                                                                56
MY CONSULTANCY
          PAYE TAX CODE CHANGES

 • Changes to PAYE Regulations for tax codes
 • Will apply from 6 April 2011
 • Code 0T to be operated instead of Code BR (basic rate)
 • Code BR deducts 20% from £1 or £1m and more!
 • Code 0T is no allowances, like BR, but
 • Code 0T will deduct tax at BR up to the BR limit (£35,000)
 • Code 0T will then deduct tax at HR (40%) between £35,000
   and £150,000 and finally,
 • Code 0T will then deduct tax at 50% on any income over
   £150,000
                                                          57
MY CONSULTANCY
           PAYE TAX CODE CHANGES

                                Current Tax Code     Tax Code from
                                                      6 April 2011
New Employee who does not      BR Cumulative basis        0T
provide a P45 or completes
P46 (A or B)

Post termination of            BR                         0T
employment payment



Paid employment continuing     New code on week 1         0T
after employee starts to
receive occupational pension   or month 1 basis

                                                               58
MY CONSULTANCY
          PAYE TAX CODE CHANGES

 • A general uplift of tax codes with suffix „L‟
 • Code for emergency use will be 747L
 • Instructions for employers on form P9X(2011)
    • Go to www.businesslink.gov.uk/payeformsandpublications
 • Individual tax codes issued between January and
   March 2011
 • New tax code D1 introduced



                                                       59
MY CONSULTANCY
         EMPLOYER SUPPORTED CHILDCARE

• Tax relief is to be restricted to basic rate tax from 6 April 2011
• The restriction only applies to new employees
• Existing employees will continue to enjoy tax relief at their tax
  rate (20%, 40% or 50%)
• The restriction does not affect the exemption for workplace
  nurseries
• From 6 April 2011 tax relief will be:
               Basic rate      Higher rate          Additional rate
Weekly            £55                £28                   £22
• Only existing employees will get full tax relief on £55 per week
  or £243 per month, irrespective of their tax rate
                                                               60
MY CONSULTANCY
          P46 CAR CHANGES

 Form P46 (Car) – Notifying Car Benefit Changes
 • Form P46 (Car) does not have to be submitted to HMRC for
   changes of company cars
 • However, from 6 April 2011
 • Employers will be able to choose to submit replacement car
   information to HMRC
 • BUT
 • Submission will be online only (Details awaited)
 • Employees can still contact HMRC to ask for a change to
   their tax code!
                                                         61
MY CONSULTANCY
          IMPROVING PAYE?

  • HMRC has announced its intention to change the
    PAYE system (introduced in 1944)
  • To bring it into the 21st Century
  • Two Consultation Documents have been published
  • Both on “Improving the operation of PAYE”
  • By Collecting “Real Time Information (RTI)”
  • AAT will be responding to the Consultation


                                               62
MY CONSULTANCY
          IMPROVING PAYE?

• PAYE still works well for most employees
• More of a problem where there are multiple sources
   • More than one employment and/or pension
• Currently PAYE/NICs should be paid over shortly after
  deductions made from employees, but
• Employers report only annually to HMRC
• This results in large numbers of underpayments and
  overpayments arising and demands being issued or
  repayments made


                                                          63
MY CONSULTANCY
          IMPROVING PAYE?

 • HMRC solution is to introduce Real Time Information
 • It will collect information about tax and other deductions each
   time employers run their payroll, using BACS
 • The information will be submitted automatically to HMRC at
   the same time that employees are paid
 • Introduction of RTI is a key component in the DWP‟s plans to
   introduce Universal Credits by 2013
 • DWP will use RTI to award and adjust Universal Credit to take
   account of employment and pension income


                                                            64
MY CONSULTANCY
         ADVISORY FUEL RATES CHANGES

 • AFR‟s normally reviewed twice yearly
 • Changes from 1 June and 1 December
 • Published on HMRC‟s website shortly before the date
   of change (May and November)
 • HMRC will consider changes if fuel prices fluctuate
   by 5 per cent and
     • “We consider the price change will be sustained”
 • Employers should monitor any changes
 • Employers need to avoid overpaying
                                                          65
MY CONSULTANCY
         ADVISORY FUEL RATES CHANGES

 • AFR‟s not binding if employer can show that the
   actual cost is higher e.g. use of 4x4‟s on rough terrain
 • Employers should keep evidence to justify higher
   rates e.g. manufacturer‟s mpg details/AA fuel prices
 • HMRC stance where higher rates used without
   evidence to justify those rates
    • No fuel benefit charge if solely business miles
    • Excess taxed and Class 1 NICs charged
 • How good are the mileage records?
                                                        66
MY CONSULTANCY
         ADVISORY FUEL RATES CHANGES
           March 2011? (December 2010) Previous (June 2010)

Engine Size            Petrol        Diesel          LPG
                   128.9p 119p   135.9p 122.7p   76.3p 66.4p
                      (119.9p)      (121.9p)        (65.4p)
1,400 cc or less   ? 13p (12p)    ? 12p (11p)     ? 9p (8p)



1,401 - 2,000 cc   ? 15p (15p)    ? 12p (11p)    ? 10p (10p)



Over 2,000 cc      ? 21p (21p)    ? 15p (16p)    ? 15p (14p)



                                                       67
MY CONSULTANCY
         ADVISORY FUEL RATES CHANGES

• AFR‟s are used for making good private fuel
• HMRC will accept no fuel benefit charge applies if:
   • All private mileage is properly identified and
   • AFR‟s are used to recover the full cost of the private mileage
   • AFR‟s are not binding if the Employer can justify a lower rate
     of reimbursement
• HMRC will not accept the use of AFR‟s to recover
  private mileage if the director or employee has a „gas
  guzzler‟ i.e. 16/17 mpg and +3.0L cars

                                                            68
MY CONSULTANCY
           APPROVED MILEAGE PAYMENTS
                 OWN CARS NOT COMPANY CARS
VEHICLE            FIRST 10,000   EXCESS OVER 10,000
                 BUSINESS MILES     BUSINESS MILES

CARS                  40P                25P



MOTOR                 24P                24P
CYCLES

CYCLES                20P                20P

                                                 69
MY CONSULTANCY
         APPROVED MILEAGE PAYMENTS

• If employer reimburses less than the AMAP rate
   • Employees can claim additional tax relief
   • Employees can claim the „difference‟ between the amount
     reimbursed and the authorised amount
• Example – MYC reimburses 30p per mile
   • Employee can claim the additional tax relief due at 10p per
     mile up to the 10,000 business miles limit
   • Claim 7,628 miles @ 10p (40p - 30p) = £763
       • Tax claim @ 20% = £152.60
       • Tax claim @ 40% = £305.20
       • Tax claim @ 50% = £381.50

                                                           70
MY CONSULTANCY
         APPROVED MILEAGE PAYMENTS

• Employers do need to monitor the cumulative business mileage
  claims for P11D reporting or PSAs in case the AMAP rates are
  exceeded
Example
   • MYC reimburses 50p for all business mileage
   • Emma drives 3,872 business miles
       • Reportable excess is 3,872 x 10p = £387
   • Paul drives 28,486 business miles
       • Excess is 10,000 miles @ 50p – 40p = £1,000 and
       • 18,486 miles @ (50p – 25p)         = £4,621.50
   • £5,621 excess to be reported at P11D Section E or PSA?
                                                           71
MY CONSULTANCY
          PASSENGER PAYMENTS

• Tax relief also available for passenger payments
    • Only for necessary business travel
    • Only if the employer reimburses the employee
•   Maximum 5p per mile for each passenger
•   Travelling in company or employee car or van
•   No tax relief if employer does not reimburse
•   No additional tax relief if the employer reimburses
    less than 5p per business mile

                                                      72
MY CONSULTANCY
          NIC MILEAGE RULES AND RATES

• NIC rules differ from income tax
• NICs due on payments of Relevant Motoring Expenditure
  (RME‟s) above a certain level
• HMRC guidance states that RME covers:
   • Mileage Allowance Payments (MAP’s)
   • payments which would be Maps' except that they are made to
     someone other than the employee (but still for the employee's benefit)
   • any other payments - except payments in kind - made by you (or on
     your behalf) to the employee (or for their benefit) relating to the use of
     their vehicle, whether for private or business purposes



                                                                          73
MY CONSULTANCY
          NIC RULES AND RATES

                 NICs - rates per business mile

       Type of Vehicle             Every business mile

CARS and VANS                              40P
MOTOR                                      24P
CYCLES
BICYCLES                                   20P

                                                   74
MY CONSULTANCY
                 Payroll Year End Workshops
                 London – 26 February 2011
                 Bristol – 28 March 2011

                 Book by phone - 020 7397 3006 or
                 email   cpdevents@aat.org.uk
                 P11D Expenses & Benefits
                 London – 14 May 2011



MY CONSULTANCY

				
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