Archive for the ‘Consultation’ Category

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Summertime blues

August 23, 2017

It’s August, Parliament is not in session, Big Ben’s bongs are silent: yet there are still 62 open consultations listed on gov.uk.  Less is more, guys, please!  (At least, in the sense that we want less legislative activity and more administrative competence from our government, not that we want fewer consultations on what legislation they DO introduce, of course.)

However there are currently zero, count them, zero consultations listed from HMRC. Hurrah!  and, is this unprecedented?  Enquiring minds want to know!  The sole HMT consultation is on developing the supply of capital for “innovative firms” (Bank of Dave, anyone???)

However – should you still be sitting in an office somewhere idly reading blog entries and pretending it’s work – there is another way you can contribute to the government’s developing policy and administrative agenda: yes, you too can Help Make Gov.uk Better by joining the panel of service users contributing to their research.

Yes, I’ve joined.

No, they still haven’t found a way of listing consultations in the order in which they close.  Sigh.

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The Navy Lark

July 20, 2017

All quiet on the consultation front. Which is as you would expect, really, because this is not a government embarking on a frenzy of domestic legislation on which it needs to consult, but holding its fire ready for the transposition and/or abolition of EU law after Brexit.

Except…

…well, there are still more than 40 open consultations listed on gov.uk. There are equality and other impact assessments around the HS2 proposals, open access restrictions proposed on different Nature England sites, odds and ends of changes to the way statistics are compiled and…

This. Proposed cessation of the Ministry of Defence’s military aid to civil authorities I wondered what it might be about.  Surely the MoD weren’t going to stop helping out in times of disaster; fear, fire, foe, flood?

No. It’s an odd thing. It seems to be a proposal to stop telling us about something we’re not much interested in, but not to stop doing the thing itself.

This is an annual publication that provides information on the number of vessels boarded by the Royal Navy Fishery Protection Squadron (RN FPS) within British fishery limits, and the number of court convictions and financial administration penalties (FAPs) issued as a result of the boardings.

We are proposing to cease production of this publication

The consultation closes on 14th August and it’s only a one page document and I honestly recommend you read it in full, because, well, I just don’t get it. Under “reasons for the proposed change” it says

The number of vessels boarded by the RN FPS has fallen from 1335 in 2006/07 to 460 in 2015/16, a decrease of 66% over the decade. The number of convictions and administrative penalties has fallen from 53 in 2006/07 to 4 in 2015/16, a decrease of 92% over the decade.

The number of web-hits for the publication page has fallen from 535 in 2015/16 to 343 in 2016/17, a decrease of 36%.

Something that is happening less and less, and being enquired about less and less, so we can stop publishing stats about it? Well OK then but I still have questions. First of all, presumably people will still be able to make a request for the figures under the Freedom of Information Act (or by asking their MP to ask a Parliamentary Question). Does’t it cost more to respond on request than it would cost to carry on chucking the figures routinely onto a website?  Seriously?
Secondly, does it cost money to collect the figures in the first place? Is there some process (“Damn it Caruthers, we may have caught the blighters but there’s still a thirty-six page form to fill in explaining how we did it”?) involved in compiling the figures in the first place that’s going to be stopped?
And finally… well, Brexit, I suppose. Isn’t policing the UK’s fisheries going to be a higher priority for the RN after Brexit, and wouldn’t you therefore expect these stats themselves, as well as interest in them, to go up substantially in the next few years? Remember the Cod Wars? The timing of this seems weird to me.
But, hey, what do I know? I’m neither a fisheries nor a naval expert and maybe this all makes sense to the people who know about it. Wouldn’t you think, though, that before you issued a consultation document you might have read it and maybe wondered whether you’d included sufficient detail for other people to understand where you’re coming from? Particularly if you’re going to say “As long as there is no objection during the consultation period, the cessation of the report will proceed as planned and the June 2017 bulletin will be the final annual report produced.” No objection? None? Anyone?
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’twas the night before Budget…

March 7, 2017

It’s the night before the Budget. Why does HMRC have four open consultations on the gov.uk website?

Let’s look at them, shall we?

Withdrawal of extra statutory concessions 2017 is a call for evidence that was issued in January and closes at quarter to midnight tonight.  Unless you’re really interested in the withdrawal of extra-statutory concessions, I suggest we leave that one well alone.

Hybrid and other mismatches – draft guidance is some technical guidance for HMRC staff and for businesses on how the legislation on, er, hybrid and other mismatches will work.  It’s complicated stuff coming out of the OECD BEPS project and I really feel as if I ought to buckle down and make an effort to understand it…

However in the real world…

Simplifying the administration of Alcohol Duty published 16 February, closes 26 April.  This seems like a private conversation between the alcohol industry and HMRC but is being conducted in public for the sake of transparency.  Again, I feel as if I ought to care enough to read it through, but again…

Finally we have:

Sanctions to tackle tobacco duty evasion and other excise duty evasion launched on 17 February and closing on 10 May (according to the website) or 12 May (according to the document). Sigh.

Incidentally I notice that the list of “who should read this” starts with “The general public”.  Seriously?  Then how are they communicating that they would welcome views from the general public?

More to the point, what is it doing sitting on the website today, the day before Budget, when you’d expect there to be a clean sheet of proposals ready for the Chancellor to start overwriting the tax rules again?

Could the answer lie in the paragraph on “getting to this stage” where it says that “at Budget 2016 the government announced that they would consult on sanctions to tackle the illicit trade in tobacco and duty evasion.” And, lo, before the next Budget… so they have.

 

 

 

 

 

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New Year

January 4, 2017

It’s ‘go back to work’ time, oh joy.   The last time I looked there were 106 open consultations on the gov.uk website. If you filter by the subject area of Tax and Revenue you’ll find there are seven:

  • Technical consultation: draft regulations for the Apprenticeship Levy
  • Hybrid and other mismatches – draft guidance
  • Tax-advantaged venture capital schemes – streamlining the advance assurance service
  • Scope of VAT Grouping
  • Tackling offshore tax evasion: A requirement to notify HMRC of offshore structures
  • Simplifying the Gift Aid donor benefits rules: further consultation
  • Employment Allowance: restricting the allowance from employers of ‘illegal workers’

Yeah.  Still can’t list them in the order in which they close, though.

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Worst of all possible worlds

December 6, 2016

You will no doubt remember the six (seven, if you include the summary) consultations on the ambitious “Making Tax Digital” proposals, which closed on 7 November.  At the Autumn Statement there was nothing in the actual speech, but, buried deep in the documentation, there was a statement that the government would be issuing a consultation response in January.

This sounded hopeful, because – if MTD is to be mandatory from 2017 or 18 – then the legislation needs to go into the 2017 Finance Bill and the draft clauses for that were published today, 5th December.

But look what it says here, in OLD (The Overview of Legislation in Draft) at the end of paragraph 6.1:

To ensure that the views of respondents to the consultations are fully considered, the government will publish its response to all 6 consultations, together with draft Finance Bill 2017 legislation in January 2017.  [my emphasis]

So not only is there an absurdly short timescale for the government to consider the multiple responses it is “pleased” to have received on MTD, but it plans to bring forward the legislation, or at least some legislation, anyway, except it will be out a month later than all the rest, shortening the time available for that to be scrutinised.

Poor show all round, I say.

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Consultation trivia

November 8, 2016

So yesterday I managed to polish up the rest of my MTD responses (they were already in draft, but I’ve had the ‘flu so I didn’t get to them in an orderly sequence in the week before the deadline as I’d originally planned) and get them out the door.

I sent six emails, one for each of the six consultation documents, to the five different email addresses listed in them (the business records and voluntary pay as you go proposals share the same response address)

As the evening progressed I had three automated response (from the “process transformation”, “cash basis” and “tax simplification consultation” email addresses)

Think about that for a moment.  Ever set up an “out of office” reply on your email?  If half the HMRC email addresses don’t know how to, or can’t be bothered to, set up a “thank you for your contribution: watch the gov.uk site for the consultation response in the next few weeks” response, well, we have great confidence they can manage to transform utterly the digital offering from HMRC.  Don’t we?

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A quick note on citizen stakeholders. And, tents.

September 5, 2016

I bloody hate the term “stakeholder”.  It started off as a reasonable sort of idea, that a business doesn’t just have to answer to its shareholders but has a wider responsibility to its customers, employees, suppliers and to society in general.  The current usage of stakeholder, so far as I can see, is to mean ‘anyone who might affect or be affected by an organisation’, in other words it’s a word in danger of becoming almost meaningless.  Unless you’re HMRC.

Yes, HMRC had its annual “stakeholder conference” today.  Yes, yes, I know it’s going to look like I’m having a massive attack of Lyndon B Johnson’s tent syndrome because I wasn’t invited, but bear with me.  Whoever they invite (here’s the list from the first one, in 2013) they can’t hope to include everyone.

But they bloody should include everyone, because we are all stakeholders in – affected by the actions of – our national tax authority.  At the very least, you’d think a twenty-first century government department with ambitions to make itself one of the most digitally advanced tax authorities in the world could manage to live stream the conference so we didn’t have to follow it second hand on twitter.

Nobody cares, I think I hear you say?  Well, people don’t know what they don’t know.  I have been conducting a little experiment lately where every time I have a conversation with a small business owner (and I mean a really small business – the hairdressers and taxi drivers of this world, the coffee shop owners and pub landlords) I have asked them about Making Tax Digital, the ambitious plan to make HMRC digital by making us all keep records electronically and none of your excel spreadsheets and carrier bags of records either.  None of my small businesses had heard of MTD, unless I have prompted them with the “four tax returns a year” horror stories from the budget before last, and then it’s been a vague, might have come across it.  And then I have (to the best of my knowledge and ability) explained it, and then I have spent the rest of my visit scraping them off the ceiling and advising them to write to their MP and to answer the consultation rather than shouting at me.

In other words, no-one is interested in HMRC until it does something that affects them.  And MTD will affect us all: we are all stakeholders.  Talk to us all, HMRC: not just to the Usual Suspects but to the people who won’t know they’re interested till you interest them.  Because interested is better than furious, honest.