Working With a Let Property Campaign Accountant: What Happens, and What Drives the Cost

We’ll also say the part firms leave out. Some landlords do not need Total Books.

Most people who call Total Books about this have never told HMRC about the rent, have put off dealing with it, and are not sure whether their records are good enough to start. Those are the three things the first conversation is for.

Key takeaways

Do you actually need an accountant for this?

Some landlords do not, and we would rather say so than take the work.

If you let one buy to let, you’ve been letting it for three or four years, you have the bank statement and the letting agent statement for all of them, the ownership is yours alone, and you were plainly non-deliberate, the disclosure is arithmetic. HMRC provides a calculator. The forms are online. You can do this yourself.

That’s where Total Books draws the line. We do not take work that does not need us, and we will say so on the first call rather than after an engagement letter.

Where a landlord is better served by a firm is where any one of the following is true. The disclosure reaches back more than about six years. Records are missing for part of the period. There is more than one property, or the property is jointly owned. The behaviour question is not obvious. There is an overseas element. A letter has already arrived. Or the tax is large enough that a shift of ten percentage points in the penalty is worth more than the fee.

That last one is worth being blunt about. On a small disclosure the penalty difference a firm can influence may be less than the cost of the firm. On a larger one it is usually several times it.

What the work actually involves

The price follows the stages, not a tariff, so here is what the stages are.

Scoping. We establish when you first let, whether you’ve ever been registered for Self Assessment and held a UTR, what records exist, who owns what, and whether a nudge letter has arrived. This decides the number of years, which decides everything else.

Authorisation. Before HMRC will discuss your disclosure with Total Books, you sign a form authorising it. More on that below, because it is not the form most landlords expect.

Notification. Total Books tells HMRC you intend to make a disclosure. At this stage HMRC only needs to know that a disclosure is coming. No figures, no detail. HMRC writes back with a disclosure reference number and a payment reference number, and the 90 day clock starts from the date you receive that acknowledgement.

Reconstruction. This is the bulk of the work and the bulk of the cost. Rent and allowable expenses, year by year, for every year in scope, built into a year by year schedule. The inputs are the letting agent statement or rent book, the bank statement, the mortgage interest certificate, the tenancy agreement for the dates and the deposit scheme record where a tenant changed mid-year. Each void period is shown rather than averaged. Where statements are missing, estimates built on a visible basis and documented so HMRC can follow them.

Computation. Tax for each year on the correct basis for that year, which is not constant. The finance cost rules changed. The property allowance arrived. Rates moved. A computation that applies today’s rules to 2014 is wrong, and it is wrong in a way HMRC checks.

Interest. Calculated to the intended payment date and included. A disclosure submitted without the correct interest is rejected as incomplete, so this is not a detail.

Penalty position. The behaviour assessment, the band, and the case for the quality of disclosure reduction, set out rather than assumed.

Submission and the offer. The disclosure carries a formal offer for the full amount. HMRC’s acceptance letter and your offer together create a legally binding contract, which is why the figures need to be right before it goes rather than after.

Afterwards. Responding to HMRC’s queries, and dealing with the acknowledgement if it does not arrive within 30 days.

Cardiff, Newport, Bristol

The arithmetic is a job. Not having to ring HMRC yourself is the part most landlords wanted.

What drives the cost

Now the stages are visible, the variables are obvious.

Years. The single biggest factor. Each additional year is another set of figures, another computation and another interest calculation. A twenty year disclosure is not four times a five year one, but it is not the same either.

Records. A landlord with a letting agent statement for every year is quick. A landlord reconstructing 2013 from memory and a bank account that has since closed is slow. This is the variable most within your control right now, because a bank statement request takes weeks and starting today shortens the job.

Properties. Each property carries its own income, its own expenses, its own tenancy agreement history and often its own start date. A portfolio is not one job repeated, it is several.

Owners. HMRC takes one disclosure per person. A jointly owned property means two disclosure packs, each showing that person’s share. A married couple who let a flat together are two pieces of work, not one, even where one tenancy agreement and one bank statement covers both of them.

Complexity. An overseas property, a period of non-residence, a property that was your home for part of the time, a sale inside the disclosure period, or a company in the picture all add work.

Whether a letter has arrived. A prompted case needs more care on the behaviour and penalty argument, because there is less ground available and it matters more.

Why missing records cost money, and why they are not fatal

Missing records change the price. They do not stop the disclosure.

HMRC’s position is that where records are incomplete you should make your best estimate and use it, keeping the calculations so you can explain how you got there. The work is the explaining. An estimate with reasoning behind it is accepted. A number with nothing behind it is questioned, and questions cost time.

If you’re reading this and your early records are missing, ask your bank for a statement today and your managing agent for whatever letting agent statement they still hold. The request often takes weeks and it’s the one thing you can do this afternoon that makes the job smaller. We go through the options in disclosing with missing records.

The authorisation your tax return form does not cover

This one catches people, including people who already have an accountant.

A standing authorisation covers your ordinary Self Assessment affairs. It does not cover a disclosure. For HMRC to deal with us about a Let Property Campaign disclosure, you complete a separate form, COMP1a, which is a temporary authorisation specific to the disclosure.

It’s deliberately narrow. Only the HMRC staff working on the disclosure see it. If we are to act for you on anything else, that needs the ordinary authorisation as well.

So a landlord who says their existing accountant is already authorised is usually right about the return and wrong about the disclosure. Total Books holds an HMRC Agent Services Account for ordinary Self Assessment work, and still asks for the separate disclosure authorisation before notifying.

Do accountants deal with HMRC directly?

Yes. Once the authorisation is in place Total Books notifies HMRC, corresponds with HMRC, take HMRC’s calls about your case, answer HMRC’s queries and submit on your behalf.

For most landlords this is the part of the service they actually wanted. The tax arithmetic is a job. Not having to ring the HMRC helpline yourself is the relief. Talk to a person, not a chatbot, is the whole of our position on this.

The one thing no adviser can do is stand between you and the truth of the figures. The offer is yours, the declaration is yours, and it needs to be right. We’ll tell you if we think a figure will not stand up.

Is the conversation confidential?

Yes, in the ordinary professional sense. You can tell Total Books the whole position before anything is submitted, and we’ll tell you where you stand.

There are limits and it’s fair to name them. HMRC has been clear that it cannot offer immunity from prosecution through this campaign, and that whether a disclosure was complete and unprompted is a factor in whether it investigates criminally. Where a case looks like it belongs somewhere other than the Let Property Campaign, we will say so and route it properly rather than submit it in the wrong place. Our guide to choosing the right HMRC disclosure route covers when that applies.

Can the fee be set against the tax?

Professional fees for putting right past non-compliance are not an allowable expense against rental profits. Fees for the ordinary running of the letting business are treated differently from fees for dealing with an investigation or a disclosure.

We mention it because landlords ask, and because the answer they are hoping for is not the one the rules give.

Scope first

Let Property Campaign service

The scope is written down before the fee is

Years, records, properties and owners, named in a short scope you can hold us to. Then a figure, then the work.

See the disclosure service

What if you cannot pay the tax?

Tell HMRC before you submit, not after. This is the order that matters.

The HMRC helpline will want to talk about your current financial position: what you earn, what you spend, what you own and what you owe. It will then tell you what it expects you to pay and when. What you must not do is submit the disclosure and the payment separately without having had that conversation, because payment is due at the same time as the disclosure unless additional time has been agreed.

Ability to pay does not reduce the penalty. It is expressly excluded as a special circumstance. The two conversations are separate and both need to happen.

What happens after it goes in

HMRC reviews every disclosure. It anticipates that the vast majority will be accepted, and it sends an acknowledgement as soon as it can. If nothing arrives within 30 days, the campaign helpline is the route.

HMRC may come back to clarify points or ask for evidence, and your co-operation with those requests is one of the conditions of using the campaign. When HMRC is satisfied, it sends a letter accepting your offer.

That acceptance is not quite the end of it. If HMRC later receives information indicating the disclosure was incorrect, it can look at your tax affairs again, and the penalties then are likely to be higher than the ones the campaign offered. Which is another way of saying the same thing we say at the start: the value of the work is in the completeness, not the speed.

What happens on the first call

Fifteen minutes with Total Books, no charge, no obligation. We ask when you first let the property, whether you’ve ever been registered for Self Assessment and had a UTR, roughly what the rent has been, whether you still have the letting agent statement and the bank statement for those years, who else is on the title, and whether a nudge letter or a brown envelope has arrived.

From that Total Books can usually tell you which time limit applies, which penalty band you’re likely to be in, and roughly how big the job is. You’ll get a scope before you get a figure, and you’ll get the honest answer if the honest answer is that you can do this yourself. Anything you send afterwards goes through our secure client portal rather than by email.

Two situations, worked through

A landlord let a flat for five years, had the letting agent statement for all of them and one bank account throughout. He had never been registered and had no UTR. The work was reconstruction of five straightforward years, one computation per year, interest, and the penalty position. It ran to a few weeks, most of which was waiting for HMRC, and it was at the smaller end of what this work costs.

A second landlord had three properties, two jointly owned with a sibling, going back to 2012, with no records at all before 2018 and one property sold in 2021. That is three property histories, two separate disclosures, an estimation exercise for six years, and a capital gains position inside the disclosure period. Same campaign, several times the work.

Both are illustrative. The point is not the figures. It is that the years, the records and the owners are what you’re paying for, so those are the three things to have ready when you ask anyone for a price.

Frequently asked questions

About Total Books

Total Books is an AAT licensed practice and an HMRC registered tax agent, acting for landlords, directors and small businesses across Cardiff, Newport and Bristol. We are also a Companies House authorised agent and a Xero Certified Advisor, and we hold an HMRC Agent Services Account for ongoing Self Assessment work. Records come to us through a secure client portal rather than by email, and every disclosure starts with the same free 15 minute call.

Where to go next

If you want to see the disclosure itself before deciding, read our step by step guide to the disclosure. If you are not sure the Let Property Campaign is even the right route for you, start with choosing the right HMRC disclosure route, because submitting in the wrong place is the one mistake that is expensive to undo.

Tell us your years, your records and who owns the property. Total Books will tell you what the job is before we tell you what it costs. Book the free 15 minute call. Talk to our Let Property Campaign team

Total Books is an AAT licensed practice and an HMRC registered tax agent, acting for landlords across Cardiff, Newport and Bristol.