How to prepare a TIIN: the tax impact assessmentFebruary 10, 2017
You may remember that I asked HMRC for the current guidance on how to prepare a TIIN (this was published here on my blog) but that the guidance referred to further guidance on how to do the tax impact assessment part of the process. I have now received, by way of a further FoI request, the attached tia guidance
Note that the “redacted” areas are where the names of the particular officials responsible for different policy areas have been redacted. Apparently the “more” areas refer to links to further internal guidance which was not considered to be covered by the scope of my FoI request.
More interesting, though, is the response I had to my question of why this guidance is not part of HMRC’s routine publication schedule, particularly as the TIIN is the tax version of a Regulatory Impact Assessment, and the RIA guidance and instructions are routinely published.
We have not published this guidance routinely for two reasons. Firstly it does not affect the computation of the tax that a customer pays and is therefore of interest only to a small community. Secondly, as you point out, it mirrors cross government impact assessment guidance for internal HMRC use and is not intended to materially differ from it, except to the extent that the impact assessments provided for tax provisions are presented in TIINs, and to explain to HMRC staff how to engage the right processes to generate the impacts.
Hmmmm… I am tempted to point out that another possible reason could be that other government departments’ impact assessments are subject to external scrutiny. As impact assessment programme manager in HMRC, my job for several years included going to cross governmental meetings and saying (in effect) no, hands off, tax is different! These days? I’m not so convinced…