MONTHLY PAYROLL SUBMISSION (PIT2024 Modernisation Project) – External BRS Review – July 2023

The following points were discussed in the meeting between SARS and the PAGSA in July 2023.

File and Record Structure Principles
• File structure:
• File Header Record
• Employer Demographic Record
• Employer Declaration Record
• Employee Demographic Record
• Employee Monthly Payroll Record
• Employee Year to Date Certificate
• File Trailer Record
• Employee Monthly Record & Employee Year to Date Certificate:
• Header
• Financial Information
• Non-Financial data:
• Fixed position with a separator
• Fields that does not have a value must be indicated by two separators without a space between it, e.g. ||
• Financial Data:
• Code, value pair with a separator

Employer Declaration
• e@syFile and eFiling: The Employer Declaration will be generated by the front-end system
• Direct Channels, including API’s: The Employer must include the Employer Declaration in the submission file
• Request for Correction: For each month that an RFC is included in the submission file, a request must be sent to the SARS’ backend systems to retrieve the latest data, before the Monthly Payroll file is submitted

Unique File Id
• The Unique File Id must be unique for each file that is submitted from the Employer and cannot be re-used for subsequent files
• The response file will be used for direct channel to provide any feedback from SARS
• The file layout for the response file will be added to the BRS when direct channels are supported

Unique Employee Identifier
• The purpose of the field is to link the employee demographics record with the corresponding employee monthly data and, if applicable, the employee year-to-date data in the file
• The field must be system generated and may be in any format
• The same value may be re-used in subsequent files
• The name will be amended to be the same across all record types

Address Fields and Telephone Numbers
• Foreign Employers: Must have a local representative and address
• Structured vs Unstructured address format
• Quality of data
Minimum length of fields
• Postal codes: Type is alphanumeric and length is 10 to make provision for foreign addresses
Type is also alphanumeric to ensure that leading zeros are not dropped
Directive Fields
• Directive information on year-to-date record: Preference to include in the YTD record
• Current validation rules vs new validation rules: The validation as stipulated in the Monthly BRS are the correct validation for the field. The validation in the Filing Season BRS had to be amended because the field was initially introduced to late for payroll to incorporate the field and, subsequently, the preferred validation rule was communicated too late for payrolls to make the change before the commencement of the tax year
• “Fixed Rate” directives: Some employers have historically included fixed rate directives in their submissions

Other Fields
• Certificate Number: The same certificate number must be used for all the employee’s monthly payroll records, including corrections, as well as the YTD data
• Employment Date and Employment Termination Date: My understanding is that most employers that have seasonal workers do not terminate the seasonal workers when the season has concluded
• Rehired employees: The employer can decide whether to use one or a separate monthly payroll record if an employee is rehired in the same month that the employee’s services were terminated
• Retrospective hire: The employer must submit all outstanding monthly payroll records if an employee is hired retrospectively

Employment Tax Incentive – Corrections
Under section 9(2), if an employer does not reduce PAYE in a month while it was available, that amount must be treated as an excess in the next month.
If an employer mistakenly does not claim ETI in a month, it must be claimed in the next month (within the 6 month period).
What we are concerned with, is that the employer may not go back to a previous month and claim the ETI in that month’s EMP201. It must be claimed in the next month. If I refer to “claim”, it is the same as “utilise” in the EMP201s.
I cannot see any issue with them increasing the calculated amount in the month that they became entitled to it. But they should only be allowed to utilise it in the next month.

Monthly Financial Data Corrections
• Negative Amounts
o Based on previous discussions and the principle that all corrections must be restated, my understanding is that all corrections can be declared without using negative amounts
o The example where the employer used the incorrect source code for a non-taxable bursary must be resolved in the same manner. The incorrect source code must be restated with the correct source code in the amended record
• Gross Annual Income
o Not all annual income source codes can be defined. There are some codes that can be either a monthly or an annual income code

General
• User Guide for Employers: A separate guide will be created to cater for the additional fields that were added, to prevent confusion for Employers
• Conceptual design: The conceptual design reflect the end goal for the Monthly Submission process