Opinion Former Article

CIOT: Tax bodies make second round of comments ahead of Agent Strategy consultation deadline

Tax practitioners have submitted a second round of comments to HMRC ahead of today’s deadline for the ‘Tax Agent Strategy’ consultation (TAS)1.

In a joint letter, Anthony Thomas, President of the Chartered Institute of Taxation (CIOT), and Andrew Meeson, President of the Association of Taxation Technicians (ATT), say:

“In summary, we consider that TAS is moving in the right strategic direction and that self-serve is attractive and useful to many, but by no means all, agents, as it has the potential to save substantial time and cost. There is an overwhelming consensus that there are some fundamental issues, some of which were not flagged up in the consultation document summary, that need to be addressed before HMRC considers proceeding any further.

“In taking TAS forward, we think that there is still a need to articulate more clearly HMRC’s intended end result of the whole project. At the same time, and unusually for a project of this size, it will be extremely important to focus on much of the detail over which concern has been expressed. This is especially so in respect of safeguards, IT systems and security, before the wider picture evolves. Successful delivery will depend on resolving the concerns highlighted and gaining the necessary support from both HMRC and the professional bodies.”

In addition to issues raised in the two bodies’ initial response (see Notes to Editors), a number of further concerns are highlighted in the letter. These include a clear level of required professional standards for tax professionals both outside and within HMRC and the need for a pledge not to disadvantage those with specialist expertise who take on the toughest cases.

Nearly two thousand members of the CIOT and ATT have contributed to the response, the biggest member input the two bodies have ever had to a consultation.

Notes to Editors

1. The Government’s consultation paper, ‘Establishing the future relationship between the tax agent community and HM Revenue & Customs’, sets out proposals for the future relationship between the tax agent community and HMRC. This includes a system of enrolment of professional tax agents, with enrolled agents being granted access to a ‘self-serve’ facility. This will enable enrolled agents direct access to some HMRC systems online. This could include agent self-authorisation, seeing the full range of their clients’ payments and liabilities, and amending clients’ coding notices.

2. The key areas which the CIOT and ATT highlighted in their initial submission to HMRC are:
a. An independent board, such as the existing independent Taxation Disciplinary Board, to consider suspension and disenrolment of agents, and also the parameters for suspension, disenrolment and enrolment - essential to building trust between HMRC and tax agents;

b. How the whole process will apply to larger firms - the document seems mainly written with small firms and sole practitioners in mind;

c. The implementation of the ‘agent view’ to assess the risk which each agent represents to HMRC - if based on a simple checklist and/or poorly implemented it would damage trust;

d. Whether those with enhanced access to HMRC systems should be qualified tax advisers – there was huge support for the view that the unrepresented should have sight of the same information as the represented, balanced by a view that only those who have reached a certain tax standard should gain full access to HMRC systems. This is not about protectionism by professional bodies - it is about concern for the integrity of the tax system. We will write separately on a 'proxy for good';

e. Decisions should not be made before the consultation has run its course and further discussions taken place – the impression gained by many is that the decision to proceed has already been taken;

f. Agent authorisation – clearly HMRC will need excellent security systems so as to guard against abuse by criminals aiming to milk the tax system. These systems must not impose onerous burdens on legitimate agents who share common cause with HMRC against fraud but often feel that they are not trusted by HMRC because of the way the systems work;

g. Security of HMRC’s systems must not solely rely on agents’ security and must address client confidentiality concerns;

h. Sight must not be lost of the key HMRC service issues which are increasingly onerous and time consuming for agents; and

i. An appreciation that the tax system needs improving and that the Government has set a tough spending review, yet agents and their clients may struggle to take on further cost displacement.


3. The HMRC consultation document is available at: http://tinyurl.com/TAScondoc
4. Both the joint CIOT/ATT initial response and supplementary letter are available at: (CIOT) http://tinyurl.com/TASresponse and (ATT) http://tinyurl.com/TASresponse2

5. The Chartered Institute of Taxation (CIOT) is a charity and the leading professional body in the United Kingdom concerned solely with taxation. The CIOT’s primary purpose is to promote education and study of the administration and practice of taxation. One of the key aims is to achieve a better, more efficient, tax system for all affected by it – taxpayers, advisers and the authorities.

The CIOT’s comments and recommendations on tax issues are made solely in order to achieve its primary purpose: it is politically neutral in its work. The CIOT will seek to draw on its members’ experience in private practice, government, commerce and industry and academia to argue and explain how public policy objectives (to the extent that these are clearly stated or can be discerned) can most effectively be achieved.

The CIOT’s 15,600 members have the practising title of ‘Chartered Tax Adviser’ and the designatory letters ‘CTA’.
6. Founded in 1989, the Association of Taxation Technicians (ATT) is the leading professional body for those providing UK tax compliance services and related activities. Our members are qualified by examination and practical experience to assist individuals and businesses in complying with their tax obligations.


The primary objective of the Association is to provide an appropriate qualification for individuals who undertake tax compliance work. Those who meet the membership requirements have their qualification recognised by use of the title of ‘Taxation Technician’ and the designatory letters ‘ATT’.

The Association has recently admitted its 7,000th member and now has over 10,900 Fellows, members and registered students.


Sophia Bell
Technical Team Administrator

D: +44 (0)20 7340 0553
The Chartered Institute of Taxation
Registered charity number 1037771
www.tax.org.uk

The Association of Taxation Technicians
Registered charity number 803480
Registered company number 2418331
VAT Registration Number 497 5390 90
www.att.org.uk

1st Floor, Artillery House, 11-19 Artillery Row, London SW1P 1RT

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