“throughout the development…”

September 10, 2014

Traditionally an Impact Assessment is published with a consultation document.  But Impact Assessment for tax changes is conducted via the “tailored tax impact assessment process” and published in a TIIN “at the point at which the policy design is final or near final”.

Does this explain why there were four separate consultation documents published by HMRC without any consideration in them of the impact the proposals might have, or at least of any coherent statement of the possible impacts?

The four consultations which closed yesterday (at 11.45pm.  Because, reasons) were on four separate aspects of the PAYE regime which the Office of Tax Simplification had identified as ripe for simplification.  There were 27 pages on exemption for paid or reimbursed expenses, 21 pages on abolition of the £8500 “higher paid” threshold, 29 pages on voluntary payrolling and another 17 pages on trivial benefits exemption. They each have different officials named as lead and, aside from identical forewords from David Gauke, appear to have been written by different hands.  But although they all talk about the administrative burden saving that will flow from any change, none of them has the usual table of impacts quantifying these impacts, nor any statement of what the impact might be on equality groups or on small businesses.

I wonder what would happen if someone were to make a Freedom of Information Act request for sight of the current state of the “tailored tax impact assessment process” for each?  I’m just saying…

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