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Closed consultations

July 4, 2012

Since one of the objectives of this blog is to respond to all the government tax consultations (I had seriously thought I could look at ALL government consultations, but have you SEEN how many there are!) it’s conceivable you’re wondering about the ones that closed last week which I haven’t mentioned so far.

Here’s a quick round up.

Above the line R&D credit. Essentially the government will refund some of a large company’s research and development costs in order to encourage investment in R&D. I have nothing to say – it’s a laudable aim, a well written consultation, and includes a decent impact assessment. Stand up, R&D tax credits team, and take a small round of applause.

REITs (Real Estate Investment Trusts).  There are proposals to change the REITS regime to encourage investment in social housing.  This, again, would have been an exemplary consultation if it had included an impact assessment showing the estimated costs and benefits of the change.  Without that, in my view, the case for change is not made.

Incidentally, in passing I note that

2.34 In England, the Government has confirmed its commitment to retain the current RPI+0.5 per cent formula for social rent increases for the rest of this Parliament.

and

3.5 As mentioned above, no solely residential REIT exists in the UK. In large part, this is due to the low yield that this sector generates which is insufficient to attract investors.

Quite frankly, if I could invest my savings at RPI+0.5% I’d snatch your hand off, so I wonder whether there might be a role for someone non-rapacious (a union consortium?  A cooperative?) to set up a housing investment REIT seeking its funding from small savers.  TUC please note!

Alcohol Fraud

I’m not sure I understand why this is such a problem but HMRC looks to be working with industry to counteract it.  What they’re not doing, it seems, is looking at the impact on small firms:

Q39. If you are a small business (less than 20 employees) please provide details of the costs and impacts of this measure?

No small firms scoping meeting in advance of the consultation document?  No Small Firms Impact Test work done yet, then?

My only feedback on this consultation, then, is that it looks as if it might have left itself open to judicial review by not doing enough work with small firms at this stage.   You also might think that, given there have already been unsuccessful judicial review proceedings in this area of law – which included the allegation that the consultation and impact assessment were inadequate –  it might have been tactful of HMRC to have done rather better this time around.

Taxing remote gambling

This one is a no brainer. My only comment would be that I wouldn’t be too fussed about any responses  from industry on the difficulty of establishing a customer’s location: they already do it, as I discovered to my cost when I had a hot tip on a horse while I was on holiday in the States and found my bookie’s account was blocked – because it could already detect where I was.  Who knew that my harmless flutter would have been actively illegal in Wisconsin!

Finally there’s the closed consultation on the tax treatment of herbal smoking products.  I couldn’t really have responded to this one, because what’s being consulted on is the design of the tax, whereas what I would have wanted to respond on was the fundamental design of the policy.

Why are we taxing herbal smoking products?

Well, why do we tax tobacco?  For one thing, tobacco is both addictive and actively harmful to its users.  And so we use the price mechanism to try and dissuade people from using it – and it’s also, of course, a good little money-raiser.

So why would we want to tax herbal smoking products?

Are they actively harmful and addictive?  Doesn’t seem like it, although I’ve never smoked any and I have no particular knowledge or expertise.  Or are we actually arguing that, hey, there’s a dangerous thing that we’ve managed to price some people out of using, but they use something else instead, so we’re losing money, so we’ll tax the other thing as well???????

This is the politics of the madhouse.  But it’s not one of the elements up for consultation, because the decision is made, because

It is not intended to cover whether such changes should be made but rather how the transition can be made easier, and to provide a better mutual understanding of this segment of the market.

Now, I’m not normally a Little Englander, but see page 7, chapter 3 of the consultation, the “Legal Background”:

3.1 At present UK legislation excludes “herbal smoking products” (which do not contain tobacco) from excise duty. This contravenes European Directive 2011/64/EC (“the Directive”) which states that:

“Products consisting in whole or in part of substances other than tobacco but otherwise conforming to the criteria… shall be treated as cigarettes and smoking tobacco”

Well what genius thought that one up?  Honestly!

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Informal consultation

July 3, 2012

So I had another look at the 29th June iteration of the tax tracker and noticed this:

Heritage maintenance funds

Consultation on easing a restriction for trusts that are heritage maintenance funds and which have deferred, or may defer, capital gains tax charges arising from the resettlement of assets from one to another.

Informal

May

So it’s an informal consultation… which means there’s no formal consultation document for us to read.

What’s it all about, then?

In the 2012 Budget document it was announced that

2.76 Heritage Maintenance Funds (HMFs) – Applying with effect from April 2012, the Government will legislate to ease a restriction for trusts that are HMFs and which have deferred CGT charges arising from the re-settlement of assets from one HMF to another. (Finance Bill 2013)

OK let’s break that down.  Whatever it is will apply from April 2012 – ie it’s already in effect, whatever it is.  But it won’t be in the Finance Bill till 2013.  So far so good: a technical change can be done like that – announce it now, and legislate it later – because the few people to whom it will apply will know about it from the technical press and there’s maybe a long lead-in time for a transaction.

But what *is* the change, and who are they consulting about it?

Well I strongly suspect we can get the answer from Google: if you put in “Heritage Maintenance Fund” as your search term, the first entry you get is a link to the HMRC Instruction Manual at TSEM5800 telling you that a heritage maintenance fund is a fund set up to maintain a historic building, and that if HMRC staff come across them they shouldn’t worry their pretty little heads about them but pass them on to a specialist unit in Nottingham. (I paraphrase).

The second entry, however, is a link to the Historic Houses Association page where the HHA helpfully explain that they want these funds (which are intended to build up the money to maintain historic houses and which are therefore exempt from Inheritance Tax) to have special treatment for income tax and capital gains tax as well.  They have a lobbying paper which sets out their stall, and where they argue amongst other things “the public benefits of privately owned heritage” – to which the only answer is, surely, “well they would, wouldn’t they?”

I have no beef with historic houses or the HHA but I read between the lines that the Historic Houses Association have lobbied for changes and have succeeded in getting, not all that they wanted, but at least one small concession.

Which begs the question, with whom is HMRC and/or HMT currently informally consulting?

It’s not just a point for the policy wonks amongst us.  Essentially the government is telling all of us not to worry our pretty little heads about it.  The point of an informal consultation is to talk to the people who will be affected by a decision to make sure the legislation works in the way it was intended to work.  In effect, the government says “I’ve decided to give the Widget Industry a tax break on oak widgets but not on mahogany ones” and then talks to widget industry representatives about whether this will distort the market or have any unintended consequences for the beech-, tin- and plastic-widget makers.

What an informal consultation doesn’t do, however, is let in any light on the wider question for the citizen.

There’s no Impact Assessment with an informal consultation.  So there’s no indication of how much it will cost to give the Heritage Maintenance Funds some but not all of what the Historic Houses Association might want, and no indication of the benefits that might accrue.  A TIIN will no doubt be published in due course with the actual legislation – but, isn’t that a bit late, for legislation that won’t even be published till next year, but which is already in force?

But let’s not worry our pretty little heads about it.  I’m sure Nottingham Trusts Office and the Historic Houses Association between them have it covered.  So that’s all right, then.

There’s an easy way to satisfy the citizen that the lobbyists haven’t taken over making tax legislation.   In the written ministerial statement that introduced the TIIN for tax changes, David Gauke said:

From Budget 2011 onwards, the Government will publish a tax information and impact note for tax policy changes at the point at which the policy design is final or near final.

So, er, if legislation is going to be backdated to last April, doesn’t that mean the “policy design” is already final?

How about it, Minister?

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More smoke. A few mirrors, too.

July 2, 2012

Hey, did we notice the HMRC Annual Report and Accounts coming out last week?

OK then, let’s all turn to page 11 and have a look at the Tax Gap.  Now this, as any fule kno, is the gap between what ought to be paid, and what HMRC actually manages to trouser.  The definitions of “ought” and “trouser”, of course, we will leave for some other time when we’re feeling particularly pedantic.  Or brave.

But look at the figures at line nine or ten on page 11:

Tax gap – difference between all the tax theoretically due and tax actually collected

2009-10

7.9% (£35bn)

2008-09

8.1% (£39bn)

Yes, the gap has gone down from £39bn to £35bn.  Woo, and indeed hoo.

And now look at the line above it, where we see that my former colleagues brought in £13.9bn – and I’m going to repeat that, that’s nearly fourteen billion pounds – from compliance activity, the bread and butter work of saying “these ‘ere accounts don’t look right to me, squire…” with all the follow up high and low tech investigation and collar-feeling that might entail.  (Pause here for a moment to remind ourselves that this money is being brought in by my former colleagues, the people whose salaries we’ve frozen, pensions have cut and numbers have decimated, and who return eleven times what we invest in them.  Not that I’m biased, or anything.)

And then look at this year’s figure.  Is it more, or is it less?

This year, there was £8.2 billion of cash collected from compliance and £8.48 billion of revenue protected.

Revenue protected?

See note 12:

12 From 2011-12 onwards we will differentiate between two types of additional revenue brought in from compliance activity:

• Cash collected: The total amount of tax that HMRC collects from activity to tackle those individuals and businesses that have not paid the tax that is due as a result of tax enquiries identifying evasion; and

• Revenue protected: The value protected by activities including: seizing illicit goods, preventing erroneous payments, deterring future non-compliance, addressing avoidance loopholes etc.

So 8.48 billion is theoretical tax; tax that we might have collected from Fred because Fred was frightened off using the loophole that Harry thought he’d identified, because HMRC came down on Harry like the proverbial ton of bricks and fined him as well?  So not real money, then?

How much of the previous year’s figure was real money and how much was fairy money, too?

The ‘additional revenue’ measure employed in 2011-12 is slightly different to the ‘compliance yield’ measure reported in 2010-11. Comparing the two measures requires both positive and negative re-calibrations which, for 2010-11, had no overall net effect. Therefore the two measures are broadly comparable.

I would rather like to see the “positive and negative re-calibrations” involved in comparing the two figures but I already have two, or is it three, FoI requests outstanding and I don’t want to be a nuisance.  But I’m sure everything is clear cut and above board.

I also have a rather nice bridge I could sell you, if you’re at all interested in real estate?

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And, look here…

June 30, 2012

They updated the tax tracker, some time after I posted about it yesterday. And, ooh, look! There are now 13 consultation documents due to be published in… “July”!

 

Sic’em, Paxo!

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June round up

June 29, 2012

Wait a minute, it’s the last working day in June?  How did THAT happen?

Yes, there was another tax tracker update, issued on 22 June, and, yes, I missed it.

(Incidentally I see I still haven’t had an answer from the Treasury to my email on 14 May:

Hi.  I have been following the tax tracker with interest (I blog about it at https://tiintax.com/) and I wondered whether publishing the tracker as a pdf rather than as a searchable part of the html content of the page is in accordance with your accessibility commitments?

It would also be extremely useful if you told people how you had updated it when you DO update it.  How about it?)

Anyway.  There were six consultations whose deadline passed this week – more of them later.

What I wanted to draw to your attention however was the backlog.  You remember the 22 consultations that were due to be published in “May”? The ones that turned into 22 consultations that were due to be published in “June”? As of this morning, there are still 13 formal consultations and three informal consultations shown as being due in “June”, which of course ends on Saturday. Going to be a busy weekend for the web publishing team, then?

Why are there a dozen or so provisions – which have already been announced, whose details are due to be discussed with the rest of us – where the document isn’t ready to be published?  Is it government indecisiveness, or HMRC lack of resource, or both?  Paxman, please note next time you have a Treasury Minister in your studio…

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Is that smoke I can smell?

June 29, 2012

It seems that every day in every way HMRC is getting better and better.  Call centres answer their phones six whole seconds faster than they did last year.  (On average.  When they answer at all.)  There are more “front-line staff dealing with tax avoidance and tax evasion” (Even if that means there are fewer dealing with routine policy work like preparing consultations or doing cost/benefit analysis of changes).

Yeah. Right.

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FSA: show me the money

June 28, 2012

So there was a tweet going the rounds this morning which said that the £59.5 million of fines which Barclays are going to pay for attempting to manipulate the LIBOR and EURIBOR rates of interest will go direct to the FSA… and reduce the fees which banks pay to the FSA for being regulated!

Let’s have a quick look.  The FSA website explains they are independent, receive no government funding, and charge fees to those they regulate and, yes, if you look at the paragraph “Who Pays for the FSA” you will see what they do with any fines they receive.

When financial penalties are imposed on firms or individuals, the proceeds are used to reduce fees in the following financial year.

So no worries, boys!  Be naughty this year, you’ll pay us less the next!  Champagne cocktails all round.

However there is this:

The FSA will be replaced by the Financial Conduct Authority and Prudential Regulation Authority in 2013. The Financial Services Bill currently undergoing parliamentary scrutiny is expected to receive Royal Assent by the end of 2012.

Yes, the FSA is going to be wound up.  At the moment, according to their annual report and accounts, they already have funding in place to cover the transitional costs of the transfer of responsibilities to the new Financial Conduct Authority and Prudential Regulation Authority that will take over their function.  So what becomes of the £59 million?

Well, under Schedule 21 Part 1 Para 2 of the Financial Services Bill (HL Bill 25) which seems to be working its way through the House of Lords at present it looks to me as if the FSA has to sort it out with the Bank of England and the Treasury:

Transfer schemes

2(1)The FSA must make one or more schemes under this paragraph for the
transfer of property, rights and liabilities of the FSA—

(a)to the PRA or the Bank,

(b)to the PRA and the Bank, to be held jointly, or

(c)to the FSA and either the PRA or the Bank or both, to be held jointly.

(2)A scheme under this paragraph made by the FSA is not to be capable of
coming into force unless it is approved by the Treasury.

(3)The FSA may not submit a scheme under this paragraph to the Treasury for
their approval without the consent of the Bank.

So perhaps one of the Noble Lords might like to check that our £59.5 million – as well as any other fines that might accrue from any other ramifications of what looks set to be a fair old scandal – go back to us, the taxpayers, rather than indirectly benefiting the people whose offences caused the fine.

If you want to ask a Noble Lord to do so, go to this list of members and pick one – they don’t have constituencies like MPs, so you’re entitled to ask any of them.  I picked the one with my surname (no relation!) but you might someone you’ve heard of who might have an interest, or simply pick one at random.  And then ask them to take an interest.  I want our money back!

UPDATE

World’s shortest campaign (or maybe “great minds think alike” – no) but George Osborne picked up the same thing in his speech on Barclays today.

Here’s what he said:

Under the previous government’s regime fines paid to the FSA are used to reduce the annual levy other financial institutions are asked to pay.

I am far from convinced that in all cases, this is the best use of the money.

We are considering amendments to the Financial Services Bill that ensure that fines of this nature go to help the taxpaying public, not the financial industry.

I have also asked my officials to urgently investigate whether this legislation could be applied to the fine imposed on Barclays Bank.

Well well – evidence that even politicians are capable of going “that’s really stupid – let’s not”.

Posted in Bit of politics, Regulation | Tagged , , , | 3 Comments »

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Open letter to Mark Prisk

June 26, 2012

Dear Mark Prisk

Did you know that you’re the Minister responsible for the Small Firms Impact test?  I just thought I’d ask.  Only I’ve always thought that the small firms impact test is a really good idea… that no-one knows about.

The Small Firms Impact Test (SFIT) is a mandatory part of the impact assessment process, which means it’s something that civil servants in other Government departments have to do when they’re thinking of bringing in new regulations, and that your civil servants over at BIS are supposed to check up on, to make sure they’re doing it right.  It hasn’t been specifically excluded from the TIIN process that applies for tax changes, so we infer it applies to tax changes too.  It would, after all, be daft if it didn’t, and I can’t see anyone persuading Treasury Ministers to stand up in Parliament and say “we’ve decided we don’t need to do SFIT for tax changes”, can you?

So, what is it?  It’s the idea that you should “think small first” – when you’re designing a new regulation, you should think about the impact on small businesses first.  Well, duh, right?

Yes, but there’s a methodology.  Really.  What you’re supposed to do is, early on in your thinking, get together a focus group of small business owners and managers, and ask them whether the idea you’re floating would affect them.  That way any consultation document you send out will be informed by the real concerns of real businesses – and you’re in much less danger of missing something.

Sounds simple, right?  But then how are you going to do it?  I mean, how are you going to find small business proprietors who have got the time and energy to come and talk to civil servants about something that might or might not affect them, way off in the future, when the idea is only at the early stages?  And you want them to talk to you without immediately rushing off to the press and going “sky falling in!  Government has decided to do something stupid again!”  And, to be honest, they’ve got better things to do with their day like, you know, running their business.

The problem is even worse if you’re HMRC, because what small business wants to come and talk to HMRC about how they run their business if they don’t have to?

So to do it right, to do it well, you need to invest in the process.  You need to hold the focus group outside of London most likely – awkward when you’ve centralised the policy teams in Parliament Street.  You need to hold the focus group outside of business hours, because in business hours a small business proprietor needs to be running their business!  You might find it easier to hold the meeting outside of a government building, or even hire a professional company to recruit people for you and facilitate the meeting.  And, as we all know, this all costs money – and can you imagine the headlines in the Daily Mail?  Civil servants claiming train fares to go to a function room and talk to business owners, maybe even over a cup of coffee?  For something that might not even come off?  Because of course one measure of success would be that a stupid idea got stomped on at an early stage – but you’re not going to want to claim that kind of success in the media, are you?

Well, maybe there’s another way of doing it.  Use email, or twitter?  I know your own twitter account hasn’t sent a single tweet yet, but there are lots of MPs who are happy to use the technology and maybe one of them would show you how.  But, again, you can’t get that kind of confidential early-days idea-floating discussion with someone on twitter – one “what do you think about this?” and the twitterati will eat you up if they think you’re asking something stupid.

So how DO you get the Small Firms Impact Test done?

I imagine if you ask your officials they’ll tell you it’s all working wonderfully well.  I imagine, though, that if you ask to sit in on the next SFIT focus group meeting – ANY meeting, any department – you’ll find your diary stays empty for a long, long time.  Because, to be honest?  I’m not confident anyone actually does it at all.

Which is a shame, because it’s a good idea.

Regards

And that brings me to my next consultation response, which was to the third consultation which closed on Friday, the consultation on “Simpler Income Tax for the Smallest Businesses”.  This one was written in the usual HMRC “talking to accountants and tax professionals” register rather than in the kind of language affected businesses might be able to understand.  I thought it was a wasted opportunity, and if I were Mark Prisk I’d be asking my officials to bring me the account of the SFIT meeting that led to it.

Here’s what I sent:

This is an individual response to the consultation and will also be published over the next couple of days (with commentary) on my blog, http://tiintax.com.

It is disappointing that you don’t seem to have involved small businesses in the consultation in a more imaginative and direct way.  Did you do a preliminary “small firms impact test” scoping meeting as recommended in the BIS guidance on the small firms impact test?  I suspect not, because the document itself seems over complicated and technical: aimed at accountants, not at the smaller businesses themselves.

In my view (as a new micro business) it will be unhelpful and add unnecessary complexity to offer a range of options – what a micro business wants is clear direction on what they have to do, written in a language they can understand (have you SEEN the first page on Direct.gov on Capital Allowances?  I’m a retired tax inspector and *I* couldn’t follow it!)

Simplified expenses are, according to the TIIN, going to increase receipts by 20m p.a. ie to have a negative impact on taxpayers and it isn’t really clear in the relevant chapter why that would be.  Surely it will make a difference to whether people want to go ahead with the change if they understand where the “winners and losers” will be.

Similarly there are 300m of receipts which appear to disappear from introduction of the cash basis – again, why is this?  Again, it might make a difference to the response if it was clear who would gain from the change.  Or if it’s a horribly complicated individual judgement, then you should have included in the impact assessment the costs of making these one off calculations: I suspect that if you did so there would be no clear case for change on this basis.

Impact on individuals “depends on the degree of alignment” with other measures such as universal credit – I found this to be totally unsatisfactory.  Government changes aren’t a force of nature – get on and align them!

Impact on HMRC has not been properly assessed and I couldn’t see why not?  Surely, again, this is an essential element of the cost/benefit analysis.

In summary, then, I think that the Office of Tax Simplification has identified an area where some change could be extremely valuable but that your consultation document has not taken account of the impact on small firms and as a result the case for change is not made.
Regards

Posted in Consultation, SFIT, TIINs | Tagged , , | 5 Comments »

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Only connect

June 25, 2012

Today the PCS – the Public and Commercial Services union – in HMRC – is on strike (or, as Sky news helpfully has it, “Jimmy Carr inspires thousands to walk out“)  The strike is in protest at cuts in HMRC staffing and to what they call “creeping privatisation” including two trials of using commercial services to replace HMRC call centre staff.  At the same time there is a lot of political noise about abolishing various benefits such as housing benefit for the under 25s.  The thinking around this is presumably that they can always go home to Mummy and Daddy, can’t they – an astonishing display of privileged thinking from the people who have never had an actual proper job in their lives.

Twitter, as ever, summed it up in 140 characters: ” Cutting housing benefit to under 25s might save you £2bn.  Well done.  Collecting the tax will save you £76 bn.  Happy to help.”

Only connect.

Meanwhile, here is the response I sent last week to the consultation on “possible changes to income tax rules on interest” – yes, I responded to all the ones that closed on Friday, I just didn’t have time to blog about it last week!  But there is a connection to today’s action, in that this is yet another consultation document that has a sloppy impact assessment that doesn’t make any compelling case for change, which is of course the point of doing the thing in the first place.  There’s an inbuilt cost to businesses and the rest of us in making any change to tax law at all – the cost of people having to learn about the changes and implement any changes to their own systems when they could otherwise be spending their time making widgets and earning profits.  So it’s one of the basic tenets of better regulation that you only make changes when the benefits justify the costs.

Is the current crop of consultations a bit woolly on the whole cost/benefit analysis side because they’re just going through the motions of consultation, or have they genuinely not got the resources any more to do the basic analysis work that ought to underpin any changes to legislation?

Anyone?

Possible changes to income tax rules on interest: consultation response

Dear Tony

This is an individual response to the consultation and will also be published over the next couple of days (with commentary) on my blog, http://tiintax.com.
I cannot see that the case is made for any changes to take place.  Although the impact assessment shows a 200m exchequer impact on the possible withdrawal of an exemption for intra-group Eurobonds, the remainder of the proposals are said to lead to “improved rules on the taxation of interest and interest-like returns” but what the “improvement” represents is not clear and there is no quantification of any impact on individuals, businesses or HMRC.  There is no cost/benefit analysis which would justify the change, and no compelling case for change is made elsewhere in the document.
It also seems to me that this is a consultation which would have benefited from a step back and look at the whole interest question in the round – the consultation is said to cover “the income tax rules on the taxation of interest and interest-like returns” but not to cover proposed “changes to the procedures for the collection of income tax deducted at source by companies, local authorities and individuals”.  Why not?  Wouldn’t it have been sensible to have looked at the taxation of interest – all interest – at once and made much more radical simplification?

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Consultation: ur doing it wrong!

June 22, 2012

You may remember that at the end of April I wrote to HMRC’s consultation coordinator about the consultation on the Gift Aid Small Donations scheme?  I said that I thought the consultation was defective in terms of the government’s own commitments to using evidence-based policy-making, because it had only the descriptive elements of the impact assessment process and none of the analytical elements.  On the basis of the consultation document you couldn’t tell how much the proposals would cost and what the benefits might be, and therefore it should be re-run with a proper cost/benefit analysis.

Here is her response which I received yesterday.

Dear Wendy,

Thank you for your email in which you raise some concerns regarding the quality of the impact assessment included within the recent consultation on the proposed Gift aid Small Donation Scheme.

I have considered the issues you raise with reference to the Government wide Code of Practice on Consultations and the Tax Consultation Framework.

As you noted in your email, the Code of Practice says that, “Estimates of the costs and benefits of the policy options under consideration should normally form an integral part of consultation exercises, setting out the Government’s understanding of these costs and benefits.”

The consultation document puts forward a number of questions which were designed to inform the contents of that assessment, including particularly on issues such as the equalities impact of the measure, and the likely administrative burden on charities and others. As part of the consultation, HMRC has also engaged directly with a number of representative groups, through two public consultation meetings, held on 27 April and 17 May 2012. HMRC has also held meetings with members of the Small Donations Scheme working group (a subgroup of the Charity Tax Forum) since last summer.

Consistent with the commitments made by the Government under the new approach to tax policy making, a final assessment of the impacts of the measure will be published today on the HMRC website (http://www.hmrc.gov.uk/charities/news.htm), alongside the introduction into Parliament of the Small Charitable Donations Bill which can be found here: http://services.parliament.uk/bills/2012-13/smallcharitabledonations.html.

I have raised the points you made directly with the policy lead responsible for the consultation. Feedback such as yours also helps ensure that HMRC has sufficiently robust processes and guidance in place to support officials in the preparation of robust consultation stage assessments of the expected impacts of a measure.

The Government recognises the importance of engaging fully with individuals, practitioners, charities and other organisations in the development of tax policy.

Um… is it just me, or does that not answer the question at all???

Posted in Consultation, TIINs | Leave a Comment »

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