CIOT (on behalf of Tax Agent Strategy): Tax professionals back self-serve but only with adequate safeguards first
Tax Agent Strategy: Tax professionals back self-serve but only with adequate safeguards first
Tax practitioners have given heavily qualified support to HMRC’s plans for a system of enrolment of professional tax agents. The two main tax professional bodies say HMRC’s proposals are moving in the right direction but there are a significant number of ‘fundamental issues’ which need to be addressed first, including the need for independent oversight of the process of suspending and disenrolling agents, who has access and security. 1
The Chartered Institute of Taxation (CIOT) and the Association of Taxation Technicians (ATT) set out their views in their initial joint comments to HMRC on the Tax Agent Strategy consultation: ‘Establishing the future relationship between the tax agent community and HM Revenue & Customs’, which sets out a roadmap for the future relationship between HMRC and tax agents. Around 1,500 members of the two bodies contributed to the response.2
The consultation document sets out proposals for ‘self-serve’ by enroled agents who would have greater access to HMRC systems, together with the monitoring of agents and disenrolling of those with very poor performance.
Anthony Thomas, President of the CIOT, said:
“Our members have indicated to us that they are generally happy with the direction of travel of this consultation, but have serious and real concerns about the mode of transport.
“Tax advisers have indicated that they are not interested in the sweetener of self-serve if it is part and parcel of an unpalatable package which will only manifest itself at a later stage.”
Andrew Meeson, President of the ATT, said:
“We welcome the consultation and that HMRC are trying to find solutions to the problems in the tax system. Our members appreciate that something has to be done to improve matters, as indicated in the recent Treasury Committee report.
“It is important that some key issues are agreed at the outset. There needs to be an independent board to police agent disenrolment and suspension from access to HMRC systems. It needs to be clear who will have access to self-serve: many feel strongly that the unrepresented need some access. And we need reassurance over security of data within HMRC systems if these are opened up to all agents. Until these issues are resolved no professional agent will want to be a part of the system.”
Notes to Editors
1. The key areas which the CIOT and ATT highlight in a letter accompanying their 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.
2. We contacted every member by way of our hard copy magazine and the vast majority by email. Our members contributed comments by various means, including:
· Completing a full detailed survey or a shorter survey;
· Phone or email contact;
· Participation in a webcast;
· Attendance at Branch discussion events around the country;
· Discussions at most of our Technical and Professional Standards committees; and
· Contributions to blogs on our website and the CIOT group on LinkedIn.
3. The HMRC consultation document is available at: http://tinyurl.com/TAScondoc
4. The joint CIOT/ATT response is available at:
http://www.tax.org.uk/tax-policy/public-submissions/2011/TAS_CIOT_ATT
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 15,400 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.
– ENDS –
Sophia Bell
Technical Team Administrator
D: +44 (0)20 7340 0553
The Chartered Institute of Taxation
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www.tax.org.uk
The Association of Taxation Technicians
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Registered company number 2418331
VAT Registration Number 497 5390 90
www.att.org.uk
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