July 16, 2015

I shouldn’t laugh, but I used to be the person in charge of project managing and proof-reading OOTLAR (the Overview of Tax Legislation and Rates) document.  I took voluntary redundancy, which of course implies that the post was abolished.  I’m not suggesting this means that no-one proof read OOTLAR for the Summer Budget but I had to laugh when I got to page 102 and found the fonts starting to wander.  The second paragraph of the impact on business for the reform of Vehicle Excise Duty is clearly in a different font than the rest of the document.  While I can’t of course say what happens inside 100 Parliament Street now, in my day that kind of error would have meant a last minute change to the document by the Treasury (because of course you couldn’t have HMRC and HMT – in the same building – being on the same computer system) .

What other last minute changes can we infer?  Well there’s a heinous page break at Insurance Premium Tax (pages 104-105) where the table of impacts loses its first two rows and becomes hard to read, and, oh look, there are the small and micro business impact and the monitoring and evaluation sections in the different font again.

My favourite one, though, is the table of impacts for the Simplification of HMRC debtor and creditor interest rates at pages 121-122 where the impacts are not quite blank but certainly empty of meaningful content.  Robust estimates of the exchequer impact are not available.  The measure is not expected to have any economic impacts.  There is no impact on individuals, households or families.  There are no equality impacts and a negligible impact on businesses and civil society organisations, no operational impact on HMRC and no other impacts.  Well why the bloody hell are you doing it in the first place then???  The point of a TIIN is supposed to be to explain what you are doing, why you are doing it at all, and why you are doing it in this particular way.  The policy rationale for this particular change is given in this lovely paragraph:

The measure ensures that rates of interest payable on tax-related debts to which HMRC is a party are all contained within tax legislation.  It also reduces the rates of interest on tax-related judgement debts owed by or to HMRC to an appropriate level given prevailing interest rates.

To which I respond: WFT?

(No, seriously, if you know why they introduced this one at all, please enlighten me in the comments!)



  1. I don’t *know* why they introduced it, but my guess would be that there are some differences in cash terms which probably pretty much net out, but there will be a bit more of a saving in terms of time and aggravation when arguing with people about whether there should be 8% interest in certain cases.

    In fact, if you can get 8% interest by going to court but only Base+2% by settling, there’s an incentive in certain cases to take the former route even though it increases legal costs all round. That probably annoys HMRC’s solicitors a bit and makes negotiations under the LSS a bit harder.

    Sounds to me like the sort of simple simplification that we need more of – saving headaches rather than cash 🙂

    • In which case why not say something like “this change supports the government’s objective of moving towards a simpler tax system by harmonising interest rates paid and charged on court and non-court settlements”? *mutters darkly about how it’s all gone to the dogs since her day…*

      • Because someone’s just run through it quickly and said “none, none, none; OK, that’s that”, and moved on to something else? 🙂

        You must have been a damn good proofreader. It took me a while to spot the font changes even when you’d said where they were! 🙂

  2. Available for proof reading assignments at an extremely reasonable rate… 😉

  3. There’s a similar suite of “nil/negligible impact” responses in all the offshore evasion condocs. Which probably highlights the weaknesses in the application of the process rather than weaknesses in the logic behind the proposals (well, some of them. Still got a bit of an issue with the strict liability offence.)

    PS Will bear in mind your availability for proofreading duties; it’s been a while since I tried to advise anyone about the tax on directors’ loins, but the memory still lingers…

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