Blimey, 2 Payroll posts in the same week! Get me!

Anyway...
Outline information first, question follows at the end.
There is some information from HRMC regarding P11d's for employers who have payrolled expenses and benefits.
The guidance states:
Quote:
Reporting any expenses and benefits that you have payrolled
You still have to send HMRC forms P11d or equivalent lists, even if you have entered into an arrangement to payroll benefits in kind and expenses. You may make yourself liable to penalties if you fail to do so.
Please follow the guidance below for submitting your P11d's depending on which scenario applies to your circumstances.
You have payrolled all the expenses and benefits paid to your employees and you file P11d information online or by other electronic means
You must:
  • telephone the employer helpline at least a week in advance of any online or other electronic submission of your P11ds, advising them that payrolling has taken place in that year, in order to avoid incorrect processing of the data.
  • complete the amount made good or from which tax deducted boxes (where this box is available for the relevant benefit)
  • complete the P11d(b) as normal, ensuring that the total expenses and benefits provided are included irrespective of payrolling

You have payrolled some expenses and benefits for some or all of your employees and you file P11d information online or by other electronic means
You must:
  • complete the amount made good or from which tax deducted boxes (where this box is available for the relevant benefit)
  • submit P11d information for non-payrolled benefits
  • submit P11d information for payrolled benefits, where the benefits that have been payrolled have a corresponding entry for "amount made good or from which tax deducted"
  • submit separately on paper P11d information for other payrolled benefits - these separate P11ds and lists must be clearly marked 'PAYROLLED'
  • complete the P11d(b) as normal, ensuring that the total expenses and benefits provided are included irrespective of payrolling

You have payrolled expenses and benefits for some or all of your employees and you submit paper P11ds
You must:
  • clearly mark all relevant paper submissions 'PAYROLLED', whether they be individual P11ds or in list format
  • complete the P11d as normal, ensuring that the total expenses and benefits are included, irrespective of payrolling



My understing is that Oracle does not support payrolling of benefits (as standard) and does not produce a report to this effect. The expectation is that if the employer is putting benefits through Payroll then they would have agreed a dispensation with HRMC so that it is not reported on the P11d.

My question is, is this correct? Is Oracle genuinely compliant (especially given the 4th bullet point under the second heading in the quoted text above)?
How are others handling this?
We have had some questions raised from our user SIG's regarding our (and therefore Oracle's) compliance given the HRMC advice.

Regards
Barry
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