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Alternative visions

November 8, 2018

The Office of Tax Simplification has a vision of the future of tax guidance.  Funnily enough it makes no mention of the previous review (the Good Guidance Guide, also known as the Anderson review) nor for that matter the Guidance on Guidance, a booklet with a yellow cover (sunflowers, I believe) which was current in my day. Maybe it’s a spinal reflex: every ten years or so someone says Something Must Be Done about Guidance, writes a report, and adds it to the shelf.

Not that I’m saying guidance has stayed the same. From manually updated HMRC manuals and printed pamphlets for taxpayers, to Tintax (electronic manuals) for HMRC staff and the grudging move to online for taxpayer guidance, to todays whizzo talk of pop-ups and voice operated search functions, and government mandated web pages with a paragraph of text written in a register with a reading age of nine, we are clearly in a dynamic system.

Which is why it’s disappointing that OTS’ review is so… static. Set up a panel of the Great and the Good. Get a Senior Manager to be in charge. Consult on whether we want HMRC guidance to be binding… It IS the twenty-first century, you know! That’s just not how things are done any more.

So here’s what I’d do. First, watermark all existing HMRC guidance with something that says “this guidance was written before G-day so may be difficult to follow. Seek advice” or words to that effect.

Second, leave HMRC manuals out of this. As I have said elsewhere, HMRC manuals are written to instruct HMRC staff how to administer the tax system, not to advise taxpayers how to interact with the tax system. It’s available to citizens under the Freedom of Information Act – that doesn’t mean it’s written for citizens to use, any more than police radio is intended for easy listening just because your radio might pick it up.

Third, make use of metadata – a webpage might well only have one paragraph of text on it, but with minimal work it should also be able to tell you when it was written (and by whom), where to go next for more detail, and have a clickable link to archived previous versions.

Fourthly, integrate guidance vertically as well as horizontally. By “horizontally” I mean across levels of expertise – taxpayer, practitioner, specialist. And by vertically I mean that even the simplest guidance should also be capable of further exploration (a “for more detail click here” link) that takes you from taxpayer to practitioner to specialist guidance and ultimately to the actual legislation. Don’t get me started about the state of the legislation online, but seriously the government buys its own legislation back from commercial firms because it can’t be arsed to update it properly and talk about don’t spoil the ship for a ha’p’orth of tar.

Yes, set up a supervisory panel… of retired teachers and other similar volunteers. Not the “tax community” who are big enough and ugly enough to argue their own corner with the revenue. No, the voices that aren’t being heard here are the taxpayer community, the actual citizens affected by this, who may have strong views on how they want to find out about the legislation that affects them.

And then write the new stuff collectively. Or, rather, keep guidance divided into three parts. The simple instruction/write according to gov.uk standards so a nine year old can read it/drop down and pop up help that comes with the HMRC forms, fine. That’s a customer service function. Fund it. Let HMRC write it. It will pay for itself. The HMRC guidance for its staff? Leave it alone: let HMRC keep it, use it, update it, and publish it under FOI. But don’t mistake it for taxpayer guidance. No, that’s the third layer: the “can I claim for a painting under the plant and machinery rules” “is there still a tax exemption for keeping a horse” “how do I claim for research and development” level of guidance.

Which – it’s the twenty first century after all – we should wiki.

Yes, you read it right. Use the wikipedia model. When I was last an HMRC policy worker, we actually had a wiki, sharing internal advice across different government departments. My staff wrote the guidance on how to produce a TIIN and kept an eye on any edits, but it was helpful for the people who “owned” the policy on, say, equality to be able to edit or expand on or add links to the relevant bit of the guidance rather than one person have to know everything about everything.

Set up a tax guidance site on the wikipedia model. How to stop people trolling it? Sign in via your taxpayer ID (the government gateway or equivalent) How to tell whether it’s accurate? It’s a dynamic system but it’s hallmarked with the date and time and name of the last person contributing, and with specific rules about how a page may be edited and why. It’s very far from perfect but then so is HMRC’s existing guidance. So, yes, let’s have a collaboration between the tax profession, HMRC and the interested taxpaying population. But let’s do it twenty-first century style.

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