What I did on my holidays, part one

August 4, 2014

The Direct Recovery of Debts consultation closed on 29th July, while I was still on holiday.  Here’s what I sent: I won’t reprint the correspondence I sent to the consultation coordinator until I hear back.  I’m assuming there’s some reason why no-one has answered me on the technical consultation issues so I’ll give them a chance to go “eek!  we printed the wrong address!” or “we promoted her and forgot to appoint a new coordinator” or whatever it is, and get it sorted first…

Anyway, this is what I sent:

  1. I am writing in response to the Direct Recovery of Debts consultation document.  I see that, although on the face of the document is says “closing date for comments: 29 July 2014”, nevertheless the landing page on gov.uk now suggests that the consultation is closed because it ran from ” 6 May 2014 12:00am to 29 July 2014 12:00am”.  I am assuming that, since the consultation document itself is signed off by the responsible Minister, it takes precedence over the (mis)information on the webpage and that I am therefore in time to have my response considered.
  2. I have written about this consultation before, at https://tiintax.com/2014/05/09/here-we-go-again/, and the content of that blog entry forms part of my response.
  3. Please note that I wrote to the HMRC consultation coordinator on 9th May, and again on 12th May, with a number of technical issues about the consultation process.  I am surprised to find that, to date, I have received neither acknowledgement nor response.  I also wrote to you personally about this failure, at this email address, on 19th June (in case there was some technical problem with the consultation coordinator email address) but again received neither acknowledgement nor response.  Please note therefore that the government do not appear to have met the legitimate expectation that they will abide by their own consultation rules and consider whether the consultation should in fact be re-run in full compliance with the published processes.
  4. Assuming you go ahead with policy development, the two suggestions I have for improving the proposed process are as follows:


(1)       Cap the total number of cases for which direct recovery can be used at the 17,000 p.a. suggested at 2.12 of the condoc.  This will ensure that the process does not suffer from “mission creep” and become normalised without further democratic discussion and agreement.

(2)       For an initial three year trial period, restrict the power to non-natural persons i.e. to companies and LLPs etc but not to individuals.


It seems to me that these two simple limitations to your proposed power, perhaps in conjunction with a sunset clause so the power can be reviewed after a three year period, would reassure the public that you were being proportionate as well as relentless, and nevertheless allow you to achieve your stated aims of recovering money due from the worst offenders.


I look forward to hearing from you that this email, at least, has actually been received!





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