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!


Fox, henhouse?

May 21, 2016

Just on my way out the door for a fortnight’s break, but before I go, in what world is the HMRC Large Business Director a suitable job for an external candidate?  Someone from, oh, I don’t know, a large business, perhaps?  In the way that we recruit benefit recipients to manage benefit offices and ex-offenders to run the probation service?  Or even students to be on the governing bodies of schools?  Here’s the advert: https://www.civilservicejobs.service.gov.uk/csr/jobs.cgi?jcode=1494432

And here’s the good bit from the person spec: they want someone who, amongst lots of other things, will

Influencing the department’s strategic direction, in relation to large business work and more generally including through contribution to development of Budget propositions.

See you in a fortnight, probably.  Play nicely!



May 17, 2016

The guidance for the Civil Service on the so-called “purdah” period before the EU referendum is contained here, in the letter from Sir Jeremy Heywood to Sir Nicholas Macpherson dated 23 February.  It is slightly different from the usual election guidance in that it acknowledges that Ministers can be arguing either side of the case and still expect support (support in the sense of provision of information and services, not in the sense of  cheerleading or even agreement) from their Departments.

Consultations on tax changes are usually in the “don’t publish” category before elections (“government consults on whether to give us all £5000 after the election.  And a pony!” doesn’t go down well with the other parties, after all.)  But equally, this is the time of year you would be hoping they would publish the batch of any consultations coming out of the Budget, so that people have time to look at them before they go on holiday and get a response in before the Autumn Statement.

So what have we got?  Not, frankly, a lot.  The first date is the closure date, not the publication date, of course.

(plus the one about licensed tobacconists I have already briefly discussed here, a purely HMT consultation about corporate contributions to grassroots sports, and a joint DCLG, HMT and VOA consultation on business rates and revaluation)

Is that the right number of consultations for this time of year, with a referendum on the horizon?  Too many?  Not enough?  Who knows!  But it puts an idea into my head.

First of all, enough with the fiddle-fiddling around with bits of the mechanism, like a hobbyist playing with his hi-fi.  It doesn’t matter where you position the speakers, where you put your chair, whether you can hear a difference between the CDs and the vinyl and whether or not you carefully place a sixpence on the record arm.  Stop playing with the system for a moment and just listen to the music!

The tax system, in this analogy, is a complex orchestral piece that will never be finished and never be perfect.  It’s creaking along, and all you are doing by fiddling with it is stopping it from falling over altogether.  Maybe instead of a “purdah” we could have a self-denying ordinance and simply Stop Changing The Tax System for a while: how about, for the rest of this Parliament, say?  Give it a rest!  Listen to the silence!

Yes, I know HMRC and the Treasury will argue they need to stop up the holes that busy people keep nibbling away at the walls.  I call bullshit.

Let’s find out how much it costs to pass a piece of legislation.  Yes, I know all about administrative burden, but I’m not talking about that.  I’m talking about “legislative burden”, if you like.  How much does it cost us, the taxpayer, to have HMRC issue a consultative document and read and analyse the responses, for Ministers to reach a decision on whether or not to go ahead and give instructions to continue, for MPs to sit in Parliament and discuss it, for the building not to fall down round their heads while they debate it, for Hansard to report it, for Parliament TV to broadcast it, for it to be printed onto archival quality paper and on vellum and for someone to walk round to Buck House and wait while her Majesty puts her signature on it, for it to be printed and put on sale and put onto the internet…

Let’s look at the TIINs.  Let’s add the legislative burden to the administrative burden and then take away the exchequer impact, and let’s think of a number.  Say, what, ten million quid a year?  Let’s simply make it a rule that no tax legislation will be put before parliament unless the TIIN shows that, after netting off the legislative and administrative burden, the change will bring in at least ten million quid a year.

Tax simplification?  It would be a start.


and another thing

May 13, 2016

A correspondent reminds me that, not only is HMRC  haemorrhaging newly-trained (and expensively-trained) younger staff, it is also stiffing its older and more experienced staff too.

Here’s how it works.

HMRC declares that they will be setting up a new Regional Centre in Shinytown.  There will be three thousand staff, lots of exciting career development opportunities, a bright and glorious future…

….except you work in Grotsville.  It’s sixty-five miles away, but you could theoretically drive there in less than an hour, if everyone else didn’t have the same idea at the same time.  And you had a car.  What you actually have to do is walk twenty minutes to the station, take a two hour train ride and then a twenty minute bus ride plus a five minute walk.  And then the same in reverse.  Every day.

Well you could move house, yes, but HMRC won’t pay for it, and anyway the kids have exams.  So you could maybe work in Shinytown and live in Grotsville for a couple of years while the kids finish their exams and *then* move?  You can eat the five hours a day travel time, for a while, if you have to.  What you can’t eat is the six grand a year train and bus fares you’ll have to pay, not when your salary has stayed the same and your take home pay has actually gone down for the last couple of years.  I mean, you’re well paid compared to some people, but not as well paid as all that.  (Remember when MPs’ salaries used to be tied to yours?  You have to laugh, or you’d cry.)

But the last straw – and I mean the last straw, the one that actually broke you – is this.  You’re not being offered a job in Shinytown at all.  No, HMRC is recruiting – something like 9000 shiny new staff to sit in its shiny new offices, with no background or history in how taxes work or the department’s history and ethics and all that canteen culture stuff.  No.  Shinytown will be opening next year whatever.  Grotsville won’t shut till 2020.  Until then, you’re stuck.  Oh, yes, didn’t we say, you can apply for a job in Shinytown and, if you get it, travel at your own expense to the land of career development opportunity.  Or you can stay in Grotsville till it rots, till the last moment when the doors are about to be shut, at which point you’ll be “redeployed” to Shinytown.  If there are any vacancies…

Remember that Dilbert cartoon about how it turns out employees *aren’t* our most valuable asset after all? I couldn’t afford the fee to reproduce it, but here’s the link to look at it for yourself http://dilbert.com/strip/1993-03-03


Value for money

May 10, 2016

“A man who knows the price of everything and the value of nothing” is, famously, the answer to the question “what is a cynic”: perhaps, however, it should be the answer to the question “what is an austerity politician?”

As a retired tax inspector and trades unionist, I still receive copies of ARC news, the journal of the union of senior HMRC professionals, and the latest issue dropped on my doorstep over the weekend.  There is an interesting article on HMRC’s approach to flexibility.  (Essentially most tax professionals could do most of their work from wherever they happened to be, if HMRC provided them with the modern computer and communications equipment to support them and didn’t treat them like children who need to be under the grown-ups’ eye.)  However the passage which interested me was this, and I hope they will forgive me for quoting it in full.

I’ve even heard suggestions that some folk, about to come off the department’s key training scheme as Grade 7s, have been told they are likely to be placed straight into the redeployment pool.  We can’t stop the private sector poaching our trainees – after all we recruit great people, we provide great training and then we pay well below the market rate – but it does seem quite a perverse approach to put someone through this expensive training process only to say, in effect, “we don’t want you”.

So let’s get this straight.  The government pays to recruit people into a career as a tax professional.  It trains them, expensively (because they are a cost to the department in salaries, accommodation and the provision of training and mentoring but are not yet producing the kind of tax yield we get from full tax professionals).  Then, at the point where their training is complete and the investment might start to pay off, we tell them they’re no longer required?

You see, I suppose it could be some kind of machiavellian plot to ensure that the entire tax profession was socialised into the HMRC way of thinking.  It could be, I suppose, if we believe HMRC to have sufficient institutional self-awareness to understand institutionalisation and understand that it actually has a viewpoint.  Why would the industry trouble to support trainees through long and expensive tax training if it can poach HMRC’s, just at the point where they’re trained but not too expensive?  But, ha ha, they all have imbibed the HMRC values with their mother’s milk and will carry on the rest of their careers believing that HMRC is right and the rest of the industry is wrong???

No, I didn’t think so either.  Dear tax industry: get poaching!


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