HMRC do not have any facility to process a zero return! We still receive receive P 35s for businesses that stopped payroll years ago. Just notify them There is no facility for filing blank P35's online, which would save lots of stress when clients receive the £400 penalties even though they are cancelled without too much drama.
The scheme can still be kept live for subsequent years' returns. Last filing season I faxed the offices with details of a few clients who were registered as employers but didn't need to submit P35's.
Only one ended up with a penalty notice and it will be withdrawn. We contacted the relevant tax offices and they sent us a blank P35 for the clients concerned these were completed as nil and signed by the client and returned to the tax office before the deadline.
We have done this for the last couple of years with no problem.
We deal with multiple tax offices so its not just one office accepting this.