HMRC requires nil ISA14 annual returns by 5 October

HMRC now expressly tells ISA managers to submit an ISA14 annual return and claim even when no tax is due, including a nil returnGOV. Fully completed forms must reach HMRC by the following 5 OctoberGOV for income paid in the tax year ending on 5 AprilGOV. Managers who previously treated the absence of a repayment claim as a reason not to file should review their annual return arrangements.

The previous guidance described an ISA14 claim as necessary only where UK Income Tax had been deducted and no interim claims had been made, or where the annual claim consolidated interim claimsGOV. The revised instruction instead presents filing, including nil returns, as mandatory under the ISA RegulationsGOV. HMRC requires a return of income within six months after the year of assessment endsGOV, together with an annual claim establishing the total repayment dueGOV. The change clarifies HMRC's filing instruction against that existing statutory requirement.

The annual claim consolidates the year's interim claims. Managers must include the amounts already claimed and reconcile them against the annual entitlement; where interim repayments exceed the amount repayable for the year, regulation 26(3) requires the excess to be repaid with the claimLegislation. The ISA14 must be signed by an authorised signatory already notified to HMRCGOV. HMRC also expressly requires a nil claim where the manager did not manage any ISAs during the tax yearGOV.

Failure to file has consequences beyond a missing form. HMRC says it will stop further interim payments until it receives a fully completed ISA14GOV and may issue a notice comparing interim payments with the lower amount it considers due. If the return and annual claim are still not delivered within 14 days of that notice, regulation 26(5) makes the difference immediately recoverableLegislation. HMRC may also withdraw the manager's approval for failure to make an annual claim.

Insurer managers and insurers providing ISA policies to other managers claim UK tax and foreign withholding tax on income referable to ISA business from their tax office, with guidance on form R19 and in the CT61 notes. The ISA14 nevertheless includes provision to account for basic-rate tax on chargeable events involving ISA insurance policiesGOV.

HMRC identifies the ISA Regulations as the basis for mandatory ISA14 filing.