Consultation: ur doing it wrong!

June 22, 2012

You may remember that at the end of April I wrote to HMRC’s consultation coordinator about the consultation on the Gift Aid Small Donations scheme?  I said that I thought the consultation was defective in terms of the government’s own commitments to using evidence-based policy-making, because it had only the descriptive elements of the impact assessment process and none of the analytical elements.  On the basis of the consultation document you couldn’t tell how much the proposals would cost and what the benefits might be, and therefore it should be re-run with a proper cost/benefit analysis.

Here is her response which I received yesterday.

Dear Wendy,

Thank you for your email in which you raise some concerns regarding the quality of the impact assessment included within the recent consultation on the proposed Gift aid Small Donation Scheme.

I have considered the issues you raise with reference to the Government wide Code of Practice on Consultations and the Tax Consultation Framework.

As you noted in your email, the Code of Practice says that, “Estimates of the costs and benefits of the policy options under consideration should normally form an integral part of consultation exercises, setting out the Government’s understanding of these costs and benefits.”

The consultation document puts forward a number of questions which were designed to inform the contents of that assessment, including particularly on issues such as the equalities impact of the measure, and the likely administrative burden on charities and others. As part of the consultation, HMRC has also engaged directly with a number of representative groups, through two public consultation meetings, held on 27 April and 17 May 2012. HMRC has also held meetings with members of the Small Donations Scheme working group (a subgroup of the Charity Tax Forum) since last summer.

Consistent with the commitments made by the Government under the new approach to tax policy making, a final assessment of the impacts of the measure will be published today on the HMRC website (http://www.hmrc.gov.uk/charities/news.htm), alongside the introduction into Parliament of the Small Charitable Donations Bill which can be found here: http://services.parliament.uk/bills/2012-13/smallcharitabledonations.html.

I have raised the points you made directly with the policy lead responsible for the consultation. Feedback such as yours also helps ensure that HMRC has sufficiently robust processes and guidance in place to support officials in the preparation of robust consultation stage assessments of the expected impacts of a measure.

The Government recognises the importance of engaging fully with individuals, practitioners, charities and other organisations in the development of tax policy.

Um… is it just me, or does that not answer the question at all???

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