Holiday reading?

July 20, 2016

If I’m reading the Parliament website correctly (and always assuming nothing has changed with the change of Prime Minister), then Parliament “rises” – goes on holiday – tomorrow, 21st July.  They will be off for the summer, coming back briefly for ten days in September before the party conferences, until term starts properly again on 10th October.   (And even then the poor dears will need a break for a week in November – what DO they do all day! – to see them through to Christmas.)

It really makes you wonder about the 65 open consultations listed on the gov.uk website today, doesn’t it?  Are people really going to give up some of their time to give their views on, say, the future of the inter-city West Coast rail franchise (closes 8th August) or the Personal Independence Payment (PIP) assessment: second independent review call for evidence (closes 16th September) when the Minister who signed off on the actual consultation may not be in place when the results are in, and in any event policy priorities are likely to have changed?

HMRC has six open consultations: each of them opened on 26th May and each has a closing date in August (and, great flying spaghetti monster, after all this time and a positive recommendation from the House of Lords Merits Committee why can gov.uk STILL not manage to let you list consultations in order of closure date???)

HMRC also has a new minister: Jane Ellison MP, the new FST.   Maybe the most useful thing she could do on her last day before the recess might be to have a quick look at the six consultations, check whether they still align with the new priorities she’s (presumably) going to be setting for the department, and decide whether they need to go ahead.  It’s my guess that a notice on the website (plus an email to “stakeholders” and other “usual suspects” who might be working on responses to the consultations) to the effect that they’ve been put on hold: take the summer off and come back in September… might be quite welcome.  What do we think?


Industrial strategy

July 18, 2016

The new mission statement for the Department of Business, Energy and Industrial Strategy is interesting (read it here).  I’m particularly thinking about the first article:

developing and delivering a comprehensive industrial strategy and leading the government’s relationship with business

which is really two different things but they’re closely related enough that I can see why they put them together.

The new Minister, Greg Clark, has a statement on the website which basically could be translated as “squee!” which is all you would expect in your first day on the job.  However there are a couple of ways that a newly-energised BIS (oh all right, BEIS) could usefully interact with the tax and benefit system.

“Leading the government’s relationship with business”?  Maybe some bilateral talks with HMRC about their relationship with businesses, perhaps aiming to rebalance the energy which goes into large and small businesses.  What do I mean?  Large businesses get a customer relationship manager, they get to have “non-statutory business clearance” discussions (but never “sweetheart deals“): small businesses get self-service on a website.  What could they do in practice?  Are there any “quick wins”?

Well, maybe it’s time for an external look at the Administrative Burdens Advisory Board which is supposed to give HMRC an objective stakeholder view of the burdens they place on small business.  While they did sterling work back in the days of the Labour government, when HMRC had a series of “new relationship” papers at successive Budgets, setting out the work they were doing to cut the measurable admin burden by 10%… now?  Maybe the membership needs a refresh, the remit needs a wash and brush up… The telling thing for me was that ABAB – the small business champions – and the EU VAT Action Group – the quintessential small and micro business group – had never heard of each other when I posted the ABAB survey on the EU group Facebook page.

Secondly, as you will know if you have been a regular reader of this blog, my major bugbear with the HMRC relationship with taxpayers is the “stakeholder” model, which seems to me to resemble the pre-revolutionary France “estates” model.  It’s possible to make your voice heard in HMRC and the Treasury, but your voice will be listened to a lot harder if you’re a member of a big city legal firm, a major accountancy firm or body, or a trade association.  It doesn’t have to be that way: it would be perfectly possible for HMRC to get views and opinions from small businesses, but it takes time and money and effort: it takes going outside of London and outside of business hours and outside of the civil service comfort zone.  It takes explaining the issues in plain English to people who aren’t going to fall over themselves with delight at the thought of talking about tax but who are going to be interested when you let them know how it connects with them and their lives – and who are going to be bloody furious if they only get to read half-informed journalism instead.

So those are my suggestions for the new Department’s “we lead on relationships with businesses” chat with HMRC: have a look at the allocation of resource between small and large business, and at the “stakeholder” concept.  But by the rule of three, this sort of article ought to h ave three ideas, right?  Well here’s a Modest Proposal for the “industrial strategy” part of the remit.

Why don’t unemployed British people take jobs fruit picking?  Why do farmers complain that they only take on foreign fruit pickers because British people won’t take the work?

This is a question only asked by people who have never been unemployed (or at least not in the modern “austerity” age of unemployment).  If you are on JSA  or Universal Credit you’re in a binary system: either you have a job or you don’t.  Who would take the risk of taking on two weeks’ work picking fruit at minimum wage if they are then going to have to re-start their application for benefits from scratch, including waiting six weeks to get anything at all…

If you had a basic income (give everyone ten grand a year instead of a tax allowance or benefits, and tax them at a moderate rate on anything over that) then your fruit picker would be two weeks better off from their two weeks work.  And you could go back to having useful offices called Labour Exchanges, whose job was actually to find you a job…


Theatre of cruelty

July 6, 2016

I apologise for the hiatus on this blog, but honestly the world has become too bizarre to be encompassed by bloggery.  I shall return when reality reasserts itself, or when I get used to the new paradigm of chaos.  If there are any upcoming consultations you’d like me to eviscerate, feel free to ping me in comments and I’ll take a look.

In the meantime, in the immortal words of Bill and Ted, be excellent to each other.


Quick update

June 1, 2016

Just a quick update to say that I have now received an acknowledgement of my response to the Land Registry consultation.  Nothing so far from the BIS consultation coordinator about why there were two different consultation email addresses on the website and what assurance there is that all our responses were received.

If you responded, I strongly suggest you check: did you get an acknowledgement?  Even if you didn’t explicitly ask for one, re-send your email to lr.consultation@ukgi.gov.uk with a copy to the BIS consultation coordinator angela.rabess@bis.gsi.gov.uk and make sure.

If you responded and did get an acknowledgement, please let me know in the comments below – and which address did you send it to?


Land registry: and another thing

May 27, 2016

The Land Registry privatisation consultation closed last night at quarter to midnight.  So I had a quick look yesterday evening to see if I’d had the acknowledgement which I’d asked for by ticking the relevant box on the response form and explicitly in the covering email.  I hadn’t.

On the principle of “it’s probably me”, I had a quick look to make sure I’d sent it to the right email address…

…and I found a curious thing.

If you look at the covering page for the consultation on gov.uk you will see you were directed to send your responses to lr.consultation@ukgi.gov.uk

(The page has now been changed to show the consultation as closed, and, dammit, I didn’t think to take a screenprint.)

But the consultation document itself gives the response address as lr.consultation@ukgi.gsi.gov.uk.  Party, brewery anyone?  I tweeted about it before the deadline (just!)  I also wrote to the consultation coordinator at BIS (named in the condoc) last night and asked for assurance that both email addresses are live and that everyone who responded will have their responses considered – watch this space.

The addresses are interesting, though.  I did wonder about the “ukgi” element, thinking perhaps that the civil service had moved to a new provider and that instead of “gsi” the format would now be “ukgi” – but that didn’t make sense when you had an address which had both “ukgi” AND “gsi” in it.  The usual format of civil service email addresses is firstname.surname@dept.gsi.gov.uk

…and so I looked again at the condoc.  Which says it is produced by BIS, the Department for Business Innovation and Skills, on the face of the document.  But on the consultation website, it’s listed as a production



May 25, 2016

I don’t want to say much about the NAO report on HMRC’s customer service, out today, except to note this:

As a consequence, though HMRC continued to live within its agreed budget, the quality of its service to taxpayers collapsed in 2014-15 and the first half of 2015-16. In hindsight, this was a mistake, and not value for money.
In other words, it prioritised “saving” money over customer service.  Because “taxpayers” are citizens with rights, but “customers” are economic units who can be ignored if they’re not profitable.

When compared to HMRC’s data on the annual cost of answering calls, the NAO estimates that the increased cost to customers was £4 for every £1 saved by HMRC over this period. (NAO)

In other words, there was – the NAO found – a direct correlation between HMRC’s “savings” and the administrative burden placed on taxpayers.

HMRC came back gamely this morning with the usual line about this all being in the past and everything today is rosy and bright…


The problem is, that as we go forward into the Brave New Digital World, we don’t really believe them.  There is evidence that they prioritised cuts over service in the past.  There are firm plans to cut staff further and relocate them where pesky customers can’t get to them for the future.  Why should we believe that the “best customer service performance in years” won’t dive back down to rubbish in the next few months and years?  As Richard Murphy suggests:

Stop the office closures.

Stop the redundancies.

Make digital services optional.

Provide the support people need.

Make paying tax possible.


Fire sale

May 24, 2016

Yes, I know I said I’d be away for a fortnight.  I am “away”, insofar as I’m away from home on a writing retreat, but my plans for a digital detox have had to be put on hold.  Because this one is important: look.  They’re after the Land Registry again.

“Have the Government failed to notice that the Land Registry has a customer service satisfaction rating of 98% – a rating that many large-scale, international and well-known organisations would love to have – that it operates at no cost to the taxpayer and that it made £98.8 million last year for the Treasury?” (Sian James, Westminster Hall debate)

When the former coalition government consulted on separating out some of the functions of the Land Registry into a company that could then be sold off, they were flooded with responses.  Responses from individuals hit three figures (trust me, I’m usually one of a very small number of individual responders, and the government has a tendency to consider individuals who respond to consultations as cranks anyway – see the response document here at para 29, which appears to dismiss the responses from the “number of respondents (who) were strongly opposed to the underlying proposals”.  Well, duh!)

However.  “91% of respondents did not agree that creating a more delivery-focused organisation at arms length from the Government would enable Land Registry to carry out its operations more efficiently  and effectively” (same response document, para 30)

So why the hell are we here again, with this consultation which closes on Thursday night (26 May 2016 11.45pm) quite explicitly seeking views on Land Registry: moving operations to the private sector

It’s blunt.

This consultation sets out options to move Land Registry into the private sector.  A sale of Land Registry is expected to deliver a capital receipt for Government.  This can be invested elsewhere for the benefit of the tax payer.  In addition, it is expected that a transaction could support Land Registry to be run efficiently and effectively and support the UK property market

A capital receipt.  If you have savings, perhaps an ISA, it’s like closing one account and opening another.  You sell the shares that are sitting in your ISA and get a sum of money you can invest somewhere else.  Wouldn’t the first question you would ask, though, be whether you could get a better rate of return somewhere else???  Do we believe the government – this government – plans to “invest” any money it gets from flogging off our assets into anything except day to day spending?

Also, it is “expected” that it “could” make it run efficiently and effectively?  When the evidence is that it is already running both efficiently AND effectively now, as a public sector organisation?  Why move from certainty to probability?

OK, let’s look at it.

Q1: Do you agree that ownership of the Registers should remain in Government?

Yes (“The Registers” are the result of the work of the Land Registry and the accumulated knowledge and data it has acquired over its history.  Of course that’s a key government task, to know who owns the land.  But the knowing is only achieved by the acquisition of knowledge: what value the registers if you then privatise the processes by which they are updated?)

Q2: What steps should government take and what safeguards should it put in place to ensure continued and improved access to high-quality and reliable Land Registry data?

Paragraph 33 of the condoc: “As the organisation becomes more digital, so the potential value of the data increases.”  It is foolish to sell off an appreciating asset: the best safeguard of its continued quality would be to retain it in public ownership.

Q3: How could government use this opportunity to improve the quality and accessibility of data produced by Land Registry for all sectors of the economy?

The government thinks we gave the wrong answer the first time they consulted because we didn’t understand the question.  The Land Registry didn’t make a “profit”, it accidentally produced a “surplus” because it did more searches than it had forecast and the surplus can’t be a profit because it’s not allowed to make a profit: “it is not currently allowed to generate a profit from core statutory functions, because fees must not be used to generate revenue for the Government to spend elsewhere – that is the purpose of taxation.”  Here’s an opportunity then: let it use its accidental surplus to improve its services and produce better quality and more accessible data.  Just don’t call it a profit…

Q4: On what basis should government manage the relationship with a privately owned Land Registry to ensure Land Registry meets, as far as is reasonable, the data quality and availability requirements of all stakeholders?

Because this works so well in other, arms length organisations, doesn’t it?  Outsourcing the buildings governments work in and their day to day management to opaque owners in tax havens really helps get the light bulbs changed and the bog rolls restocked.  Basically the story goes like this: send something outside of the public sector.  The expert staff go with it and get a stonking pay rise.  The remaining department tries to manage the relationship.  The agile private sector organisation runs rings round them, because they took all the knowledge and expertise – that the taxpayer had paid for and which is invested in the staff – with them.  The simple answer is: don’t do it!

Q5: do you agree that the suggested safeguards should be included in any model?

Q6: are there any other safeguards that you think should be included?

First, don’t sell it.  Second, if you have to sell it, supervise it.  Third, if you’re going to supervise it, make sure the supervision isn’t done only by the usual suspects: have some sort of supervisory board that includes representatives of citizen organisations as well as big businesses.  You could, for example, have it supervised by a Parliament of representatives elected by ordinary citizens… if you didn’t sell it in the first place.

Q7: Do you agree with the preferred option?

Q8: What are your reasons for your answer to question 7?

No: the preferred option is to flog off everything about the Land Registry except the actual Registers.  I much prefer the “status quo” option dismissed at para 89 because it does not meet the government’s objectives.  However the government objectives of “reclassification from the public sector” and its “clear requirement of maximising capital receipt” are not supported by evidence.

Q9: Do you think an alternative model would be better and why?

Yes: the “BBC model”.  Government should set the Land Registry free of the requirement to charge only what covers its costs and instead allow it to raise its charges by a capped formula (inflation +x%, as is done in the privatised railways)  It would remain, like the BBC, a non-profit organisation owned by the nation and run for the benefit of its citizens.  However its day to day running would be a matter for its own Board of Management and it could achieve “reclassification from the public sector”.  Maximising capital receipts would not be met, but instead it would produce an income stream.  Like refraining from selling the flat you inherited from your granny, but instead letting an agent manage it and enjoying the profits.

Q10: Are there other key costs and benefits that you think we have missed?

You were being disingenuous about the capital receipts thing at the beginning, weren’t you?  “Finally, it would raise revenue for Government that can be used to reduce the unsustainable level of public debt or be used to fund other public spending which is a key objective”.  (para 93)

Please think about going here and contributing a response to the “consultation” if you can: if all else fails and you don’t have time, simply email lr.consultation@ukgi.gsi.gov.uk with your thoughts.  Before 11.45 pm tomorrow!


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