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Outside in

November 19, 2013

Has HMRC gone to the dogs?

I keep hearing tales of mishandling of people’s tax affairs by HMRC – factually incorrect decisions, idiotic telephone handling, computer-generated correspondence tone deaf to nuance and stuffed full of incomprehensible jargon…

But then I would, wouldn’t I?  I’m writing a PhD about tax policy-making, I write a blog about HMRC consultations, and I’m an ex-Inspector, so any time the “what do you do?” question comes up in polite conversation I’m going to have to mention tax.  I’m retired (what did you do before?)  I’m a student (what are you studying?)  I write a blog (what’s it about?)

Now, when you are a tax inspector you quickly learn (and are in fact told by your colleagues) not to mention it at parties.  This is because, just as doctors never say what they do because someone will immediately buttonhole them about the odd pain they get in their left knee, so mention of tax will always bring people’s own tax questions out of the woodwork.  When I passed my driving test the examiner asked me what I did (he was just making conversation while he filled in the forms) – and then spent so long asking my advice about a capital gains tax question that my poor instructor was convinced I’d failed again!  And the “ex” part of ex-inspector means that people are, if anything, MORE inclined to tell me about their tax problems these days because I’m no longer one of “them”.

And conversations about a government department are never going to be about how well conducted it is – it’s like the old Lenny Henry joke about the policeman never pulling you over to tell you the way you took that corner was well ‘ard.  No-one makes a funny story out of how they did their tax return and it was easy and everything worked just fine.

So there are several reasons why my view of HMRC might not be accurate.  First, because anecdotage tends towards the humorous “catastrophe” and away from boring competence.  Second, because I’m a tax policy wonk and, just like the doctors, everyone has a tax story just as everyone has a human body story. (Death and taxes, universal experiences, remember.)

But my view of the Department may also be different because, when I was inside HMRC, it felt like I might be able to do something about it.  If someone said they’d had a bad experience with x I could suggest they tried doing y or speaking to so and so.  Now, I’m just another bloody civilian and I can queue up on the helpline like everybody else, so there’s also something about my own perceptions of the Department being different.

And yet… and yet…

What about Robert Smith v HMRC (TC2768)?  Yes, there was an avoidance scheme involved so I can’t say my heart bleeds for the taxpayer.  But it was an avoidance scheme HMRC knew all about, had issued a technical note on, and where the taxpayer had given enough information in his return for HMRC to have challenged him.  But – and there was actually a handwritten note on his file which said  “on sick leave 21/11/02 to 3/3/03. No action during that period and therefore SA window for Enquiry already closed 31/1/03. Too late!”  – HMRC missed their window.  By which I mean that – through HMRC management not adequately covering the sick leave of one of their officers – they missed the statutory window of opportunity to enquire into the return.  And remedied it by deciding they could make a “discovery” assessment.  While the taxpayer in me thinks, well, good, he didn’t get away with an avoidance scheme, the citizen in me thinks, hang on, whatever happened to finality and only one bite of the cherry…

No?

Well what about W Maxwell (TC2849) where one of the pieces of metadata for the case is “unconscionable”?  Mr Maxwell was a pensioner and his accountant kept telling him his tax affairs were up to date and everything was OK but in fact the accountant was seriously ill and not keeping up with his work.  The accountant then died and Mr Maxwell – who had known nothing of his accountant’s illness – found another accountant and thought he was up to date.  However he in fact made late returns (because his former accountant hadn’t made them as he’d believed) and so HMRC charged him penalties.  In spite of the fact HMRC had apparently allowed other clients of the dead accountant some leniency, nevertheless they seem to have decided to throw the book at Mr Maxwell – but, as tax barrister Keith Gordon pointed out in Taxation, “The facts were crying out for relief and it is amazing – for which I mean seriously concerning – that the case would have passed through a number of different HMRC officers, none of whom seemed to be able to act conscionably”

Get that?  Different levels of HMRC review and still no-one had the wit to say, hang on a minute, do we really want to throw the book at this guy?

No?

Well how about a deceased taxpayer whose executor sends in the trust return for her estate on paper in January when paper returns have to be in by the end of October?  An electronic return is made before the end of January – the electronic return is on time, but there’s a nasty wrinkle that means you can’t avoid a penalty for making a late paper return by making the same return electronically later.  The trustees explained they hadn’t meant the paper “return” to be taken as a return, they were just writing to make it clear this would be the last return and the estate had now been distributed, and it was the electronic return which was the actual return for the period.

Now, we could all argue this one till the cows came home, but – but, the penalty was £100, the taxpayer had died, the estate was distributed, and the electronic return was on time.  You’d have to have a heart of stone not to say “oh all right then, just this once”, surely?

No?

Well, suppose you had knowledge that didn’t make it into the report of the case: I don’t know, make up your own.  Perhaps you just didn’t like the cut of their jib for some inscrutable reason of your own – but even so wouldn’t you, at the very least, make sure that before you went to court, for a hundred quid penalty, that you had a copy of the damned return you were talking about???

15.
HMRC have produced no evidence to the effect of the return filed on 14 January 2013 was a valid return even though this is an appeal where it was clear that the nature or status of the paper document sent to HMRC was in dispute. The document itself has not been produced and there is no evidence that this document (which the Appellant described as a “copy” of the online return) was signed by the Appellant.
Those are just the examples I can find in the public record (and in Taxation, of course) via five minutes of googling.  The examples people share with me which I can’t share any further because I have no right to do so, well, they’d make your hair curl.
Is it just me?  Is it just the effect of being outside the organisation when once I was inside?  Or is there really something, well, rotten, going on?  I honestly can’t tell.

Posted in HMRC | 1 Comment »

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Get Carter

November 11, 2013

One of the things I am becoming increasingly interested in academically, and which you may have noticed as a recurring theme in this blog, is the disjuncture between people-who-know-about-tax and everybody else.  The most useful terminology I have found for this so far is to use a simile taken from Harry Potter and call the two groups “tax wizards” and “tax muggles”, particularly as the Potter analogy allows for people like me, a “squib” who knows about the existence of the tax wizarding world but doesn’t lay claim to any of its powers.

Let us thank goodness, then, for the Low Incomes Tax Reform Group, a charitable offshoot of the Chartered Institute of Taxation, which aims to be, well, I suppose the Potter analogy would be the Ministry of Muggle Affairs – to

‘Target for help and information those least able in the community to afford to pay for advice and make a real difference to their understanding of the systems of taxation and related benefits whilst working to make them more equitable and accessible for their needs.’

They supported and won a test case, TC02910: L H Bishop Electric Company Limited and related appeals (I’m afraid I can’t find a link to this that isn’t on a paid website but here’s LITRG’s press release about it) about mandation of VAT reporting online.  In other words, some people can’t, won’t or at least find it very difficult to, conduct their VAT relationship with HMRC purely over the internet and wanted the same exemption that people with religious beliefs that prevent them using computers have.  (Incidentally, I had always rather lazily believed that this exemption was in place for the Plymouth Brethren but I see from their website that apparently they have been using computers for five years now… in which case, who DOES get the “religious” exemption?  Does anyone know?)

The argument was, essentially, that people who don’t use computers because they’re old – they didn’t learn at school and they have no particular desire or need to learn now, and they find it harder to take on board new information by reason of their age – and people who have a disability – either a cognitive disability that prevents them absorbing the information on a computer screen or a physical disability which prevents them using a screen or keyboard – ought to be exempt from having to file online.  In addition, people who live somewhere that doesn’t have a broadband service sufficient to get them onto the HMRC system, again, ought to be exempt.

The HMRC argument can be summarised as: “tough.”  Or, at least,

  • ask a friend or family member to do it for you on their computer
  • use a computer in a library
  • pay an agent
  • use a computer in an HMRC enquiry centre, or
  • use the Sekrit Phone A Friend service they invented just for this case (don’t ask)

The tribunal, it’s fair to say, wasn’t impressed.  Libraries are closing left right and centre.  HMRC enquiry centres are either closed or scheduled to close.  Asking or paying someone else to make a return has privacy implications.  And HMRC inventing a telephone filing method but then not telling anyone about it, well, this is what the tribunal had to say…

435.
The current version of telephone filing, as offered to the joint appellants, requires the taxpayer to agree three months in advance with HMRC a day and time (in HMRC’s business hours) when HMRC will ring the taxpayer in order for the taxpayer orally to state the figures on the VAT return…

440.
HMRC does not accept that telephone filing is inconvenient. They point out that the HMRC agent would ring back if the taxpayer was engaged. But the protocol established by HMRC for telephone filing is that the agent will only ring back twice, and will then write a letter to the taxpayer in an attempt to re-arrange the phone call.
441.
I find reliance on the postal service to re-arrange a phone call is unrealistic: VAT returns are due on set days. Unless the taxpayer arranges the first call to be on a date long before the due date, he would run the risk that if the call has to be re- arranged, the new date will be after the due date.
442.
HMRC do not suggest that the arrangements for the re-arranged call can be made over the phone. It is not part of the protocol, and as evidence above has shown it is very difficult to contact HMRC by phone.
443.
I find telephone filing is not a very convenient option for submitting a time sensitive document, the late submission of which will incur penalties.
and then (and this is my personal favourite part of the judgement)

496. Its concessionary status was not the only controversy over telephone filing. There are (at least) three reasons why it might be unlawful:

  • It may ignore s 25(4) Value Added Tax Regulations 1994;
  • It is an unpublished and largely secret concession;
  • It may be “Wednesbury unreasonable” in that HMRC do not appear to have considered all relevant matters
Unfortunately, though, the judgement isn’t going to be much use to most people, since (as far as I understand the rather detailed technical arguments) the litigation was only possible because there was a decision by HMRC (to put the taxpayers into the first tranche of people, those who had to file their VAT returns online from 1 April 2010) whereas most people will have to file online from April 2012 by generally applicable legislation and not by an appealable HMRC decision.So…  judicial review of the legislation, would seem to be the next step for people who are affected by the change to online filing but unable to make the change by reason of age, disability, or inadequacy of broadband.

Now moving HMRC’s services online was part of a programme of change that came out of the 2006 Carter Review (which noted that:

3.7 Some people still expressed opposition, as a matter of principle, to compulsory use of online services, especially for certain groups, such as pensioners.

so HMRC can hardly claim they hadn’t been warned!)

Carter also was reporting from a different world, where online services would be accessible via free publicly funded services like libraries and HMRC enquiry centres:

5.9 We also recommend that HMRC should work with other public and voluntary organisations to ensure that access to the internet, and appropriate assistance with using IT, are available locally, for example at libraries and UK Online centres, for taxpayers who wish to file their returns online but do not own a computer.

The impact assessment for the Carter changes was updated in March 2009 and contains (at Annex C) a rather good suite of specific impact assessments including an Equality Impact Assessment and an assessment of the extent to which the proposals have been subjected to “rural proofing”.  My problem with these is that they are just words: it is no earthly use to anyone to identify that the solution may be:

through a visit to an Enquiry Centre (EC) to file (if mobility permits) or a visit by an HMRC employee with a laptop  [IA p34]

if you then close down the enquiry centres and fail to set up a mobile service of HMRC employees who can come round to your house with a laptop.

However the TIIN for the specific requirement for VAT to be filed online dismisses any concern for equality altogether:

Equalities impacts

Equalities impacts were considered in July 2008. This covered all the business taxes covered in Lord Carter’s report and concluded that the requirement to file online and pay electronically did not, of itself, disadvantage any specific group of customers from an equality standpoint (although, as with any change, some customers might need help to adjust).

Or, to put it another way, “we did this already, didn’t we?  Get stuffed.”

I look forward to seeing if the Ministry of Muggle Affairs chooses to fund a judicial review of the regulations mandating online filing.  If so, I’d be interested in seeing what they make of the equality assessment and its oh so helpful assumption that Carter is OK because HMRC thought about equality a bit in the noughties so we don’t have to bother with all that stuff any more.

Oh, and the rural proofing?

Other impacts

None.

Yeah.  Right.

Posted in DDA, Equality, HMRC | Tagged , , , , | 4 Comments »

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Not waving…

October 18, 2013

Yes, I’m still alive.  No, I haven’t posted for over a month.  Long story short: had a ridiculously bad cold at the same time as a short term contract to deliver some training at the same time as the new  university term started.  Blogging, I’m afraid, fell towards the bottom of the “to do” list and, as I never got much beyond “Work.  Eat.  Take medication.  Sleep.” I’m afraid I’ve been out of the tax consultation loop for a bit.

So where are we now?

I started off with a quick gallop through the gov.uk consultations page to see what was open and if anything was coming to a close soon…

…which gave me some odd results.  The page tells me that government has 144 open consultations today, which is a substantial number, and that ten of them are HMRC’s.  But as I glanced down the list of ten I started thinking, hang on, this is odd – haven’t I already answered this one?

So I filtered again, by “all departments” and subject is “tax and revenue”, and got a list of nine tax consultations.

Eight of which are already closed.

Um… hello, gov.uk?  I left feedback on both pages, but I think your search engine is…. (looks for polite alternative to the word that immediately springs to mind.  Settles for:) in need of some remedial attention.

All right then, let’s go back to my own laboriously constructed spreadsheet from July 22, which shows no tax consultations with a closing date after October 14th.  And then let’s go back to gov.uk and search for “all consultations” published by HMRC after 22/7/13.

This brings up a list of 16 results: seven consultation outcomes, four closed consultations and five “open consultations”.  Good: now we’re getting somewhere.

They are:

  • Tax-Free Childcare – closed
  • Alcohol fraud: next steps – closes 28th October
  • Reform of an anti-avoidance provision: Transfer of Assets Abroad – closed
  • Residence of Offshore Funds – extending the scope of Section 363A Taxation Act 2010 – closed
  • Investment Management Exemption and Collective Investment Schemes: expanding the “white list”- closed

So, sorry gov.uk, but something is going wrong with your classification system.  And now I’ve run out of time to blog for today, too, and all I’ve achieved is to identify there seems to be only one open tax consultation.

Which is, I suppose, at least something.  Sigh.

Posted in Consultation, HMRC | Tagged , | 1 Comment »

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Wizengamot

September 11, 2013

So I was at a meeting of the Wizenagemot yesterday…

Ah.  I probably need to step back a bit and explain?  You see, it’s my belief that the debate about tax is divided between two groups.  There are the tax professionals on the one hand – people like HMRC and HMT and accountants, tax specialist solicitors and barristers, tax specialists in large businesses and policy thinktanks and lobby groups.  People who understand that a painting can be “plant” and whether or not a jaffa cake is a biscuit.  Let’s call them the tax wizards.

And then there are the people who don’t understand that “there is no equity about a tax” but think that there ought to be some kind of principle of “fairness” involved.  People whose “idosyncratic and ill-informed” views about tax are “a joke to those who understand the subject”.  The tax prats .  The citizen stakeholders.  People who pay their taxes and don’t understand why everyone else doesn’t seem to have to follow the same rules.  The tax muggles.

Well, if you’re a tax muggle you may not be aware that there’s an active debate in the tax wizarding world about this thing called the Tax Gap, which is the difference between the tax that HMRC collects for us, and the tax that they ought to be able to collect if everyone paid their dues and no-one made any mistakes.  And you don’t have to be a wizard to understand that this gap is never going to be zero because, after all, nobody’s perfect, but everyone is clear that it ought to be as small as we can reasonably make it.

Ah.  And there’s the rub.  Because David Gauke, the Minister for Magic doesn’t think there’s much of a problem with the tax gap at all.  He told the meeting that the UK tax gap was “relatively small by international standards”.  (Does anyone have a source for this, by the way?)

He also told the meeting that he made “no apology” for HMRC’s staff and budget being reduced, which was a bit of a brick considering that the meeting had been called by ARC, the section of the FDA that represents senior officials in HMRC, and that their agenda was to explain that they thought they could make a big hole in the tax gap if they could just have a few more people and some decent treatment for their members.

The meeting was at Portcullis House (and isn’t THAT a fabulous building!  Wow!) and involved tax wizards from HMRC and ARC, the Exchequer Secretary, his Labour Shadow and the Chair of the backbench Lib Dem Treasury Committee, as well as Richard Miller from ActionAid.  It was chaired by Vanessa Houlder from the Financial Times and was extensively tweeted here (although not at the time – no signal inside Portcullis House).

I am not sure there was any great meeting of minds resulting from the event.  The politicians spoke to their briefs, the campaigners argued the tax gap is bigger than HMRC’s calculation, and I sat there wondering (a) what does it matter and (b) when was ARC going to get back to the “give us more resources” point?

What does it matter?  Well, everyone agrees there IS a tax gap.  Everyone agrees that it is a good thing to endeavour to keep the tax gap as small as feasible.  There is some broad agreement on what elements are included in the calculation of the tax gap so we know where to direct attention.  So what does it matter in practical terms whether underpaid corporation tax is around 3-4 billion or 12 billion?  Can we just agree that it’s either “shedloads” or “a fuckton” and that in either case we’d like some of it back, please?

Which takes me back to (b).  I was surprised, frankly, that ARC didn’t drive home their point a little more strongly.  When your Minister says he makes no apology for cutting your staff and resources, surely you exercise right of reply and say, “yes Minister, but” and then hit him with your stats?  The stats you’ve politely buried in the Notes to Editors to the press release linked in the bibliography to the polite paper you’ve put together for the meeting?  Because, you know, he won’t have read that far.  Even his staff are unlikely to have read that far.  So when you have him sitting two seats away from you, you pass him another cup of coffee and give him your elevator pitch: invest £312.3m in us and we’ll bring you in eight billion quid (£8,260m)

As Saint Sir Bob apparently never actually said “give us the fucking money!”

Yes, Minister?

 

 

 

 

[note: edited 16/9/13 to add a link to the FDA reporting of the event – first link in the article]

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

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Living in the future

August 8, 2013

Why can’t HMRC communicate by email?

Well, why can’t they?

I spent what seemed to me an unreasonable amount of time hanging on for an HMRC helpline today.  And then answered a series of questions to confirm my identity.  And then discovered the person I was talking to couldn’t actually resolve my problem, I needed to write in.

Now, why can’t I email?

Yes, yes; identity fraud, impersonation, insecurity of sending personal details electronically, blah blah blah.  (Incidentally, I can manage my bank account via a mobile phone app.  Maybe HMRC could get one of those!)

But I’d already established my identity to HMRC’s satisfaction during the phone call.  And there’s a thing called PGP – pretty good privacy – that will encrypt an email, if you’re paranoid enough to be bothered.   (Disclosure: I’m not, so I’ve never actually tried it)

Having established my identity, the operator could have given me an email address (hers for preference, or at least some kind of postbox for authenticated email) and the necessary “key” to operate the dual key system.

And then I could have sent her an encrypted email and she could have decrypted it and actually dealt with it, in the knowledge it actually came from me.   Or something.  But don’t tell me that in the twenty-first century, communicating with a government department via email isn’t possible.  It might not be convenient for the government or its departments – no doubt in this day and age the requirement to send snail-mail acts as a preliminary filter to stop those of us who might otherwise have emailed more often than the department might like…

Remember how long it took for the old Inland Revenue to adopt the technology of the fax machine?  (Those of you under thirty; it’s an old-time machine that acted like a cross between a networked printer/scanner and a landline.)  It’s time to make another leap of faith and embrace email.

Well, OK, it’s also time for me to fix the damned printer…

Posted in HMRC | 1 Comment »

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Spending review

June 26, 2013

I was watching the Spending Review this lunchtime.  Sad, yes, I know.  But none of the people in the House of Commons that I could see on the telly gave any evidence that they knew there was life beyond the Westminster bubble.  As I tweeted at the time,

The laughter and jeering on both sides of the House is offensive beyond belief. This is people’s lives you’re dickering with, posh boys.
While I was tweeting, did I really hear Osborne suggest that “some” public servants get 7% progression pay in a year?  I’d very much like to see evidence of that, and if it’s true I strongly suspect there’s an outlier being quoted as a norm there.
Let’s look at HMRC for a minute.  Here is what a tax inspector earns. Disclosure: I was on the G7 max for years… and years… and years.  Which is fair enough – I’d qualified, done a few years to get the rough edges off, and reached the rate for the job.  After that, if I wanted more, I had to get promoted (pause for hollow laughter) or get an “exceed” (performance pay) mark.  Oh, and the pay scale used to be bumped up every now and then to keep pace with inflation but that’s gone since the coalition took power – my former colleagues are still earning exactly the same as I was when I left… only now, of course, they’re taking home less, because they have to pay an extra “contribution” towards their pensions…
And no-one’s complaining about that.  It’s a good salary, and when you’re on the top of the scale you’re getting the rate for the job, and there are people worse off.  Yes, there might be a pay differential between the public servant and the accountant working for the other side, but it’s less than it used to be and there’s no-one hiring at present so there isn’t that immediate drain on the HMRC senior staff that there was when I finished my training.
But look at this, the age and grade profile of HMRC staff and you’ll see that there’s a big “bulge” of people in the G7 and G6 grades who are in their forties and fifties.  They might all have to work on till they’re 67 and 68, but I suspect a lot of them, like me, will scarper as soon as they get a halfway decent offer.  And look at the age profile of the people coming up behind them, the “fast streamers”, the bright kids they get in from university and train up to be the next generation of inspectors.
Ask yourself how they’re going to feel when they get promoted to G7 and sit there on the bottom of the scale?  There’s £8,921 between the top and bottom of the London G7 scales, £7,758 between the top and bottom of the National scale, and a whopping £14,607 between the bottom of one and the top of the other.  Yes, it happens, people in Sheffield do the same work as people in London.  So how would you feel about it?
I mean, I’m assuming the plan is to stop the music where everyone is standing right now and take away ALL of the chairs, not just one.  And then make everyone work extra hard to get that “performance pay” if they want more.  And devil take the hindmost, the person on fourteen grand less than the lucky sod doing the same job in a different place who got their foot on the ladder before the rungs were sawn off.
(Yes, all right, I’ll stop mixing my metaphors in a minute.  I get less articulate when I get cross, and I’m very cross at the moment, in case you hadn’t guessed.)
We were discussing equal pay for women in the Civil Service last week (there’s a summary of the discussion here).  I’m assuming that, since the point of the spending review was to spend less, that the government isn’t proposing to boost everyone UP to the rate for the job, thus removing the lingering equal pay issues, before imposing the ban on progression pay?
No, thought not.
Public sector unions are fools if they don’t set up a kickstarter for the legal expenses fighting fund and get the mechanism of an equal pay court case in motion.  Because austerity shouldn’t be at the expense of equality.

Posted in Bit of politics, Equality, HMRC | 1 Comment »

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…and another one

June 24, 2013

I wonder how many MPs are planning on demonstrating their constituency credentials by asking about the closure of their HMRC enquiry centre?  Here’s another one, from Penny Mordaunt, a conservative from Portsmouth North, and again the figures are interesting:

Number
2008-09 22,988
2009-10 21,855
2010-11 20,987
2011-12 20,973
2012-13 16,767

Two things interest me about this.  First, the precipitate fall in numbers of users of the service in the past year.  Do we think that might have any connection with the service’s concern with being “digital first” and the requirement to tell people to pick up the phone and speak to a distant call centre, rather than speak to the actual human being in front of them?

And, second, if you go to the HMRC page here and download the spreadsheet that seems to be the only way of finding out the opening hours of the enquiry centres, you’ll see that there are, in fact, TWO enquiry centres listed for Portsmouth, Portsmouth Lynx and Portsmouth Wingfield.  I’m rather curious as to why the Minister only reported on Lynx House and completely omitted to mention Wingfield.  But you can imagine why numbers might be problematic at Wingfield, when it’s only open two days a week.

Those figures don’t look so bad to me, actually.

Posted in Bit of politics, HMRC | Leave a Comment »

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Eleven

June 20, 2013

Bit of an interesting exchange here, between David Gauke and Shaun Woodward, the Labour MP for St Helens South.

He asks how many people will be made redundant if the St Helens enquiry centre closes, and how many people they served.  Apparently there are five jobs at risk, but the numbers of visitors is the interesting bit:

Number
2008-09 15,900
2009-10 13,315
2010-11 17,070
2011-12 14,545
2012-13 13,296

So… five people answered between thirteen and seventeen thousand enquiries.  Take the middle number, 14,545.  Divide it by 5, and you get 2909.  Divide that by the average number of working days in a year, 252, and you wind up with about 11.

Eleven people a day.

Sometimes you might deal with them in a minute – point them towards the phone.  And sometimes you might be on sick leave, in a meeting, or training.  Filling in your paperwork and doing your performance management review.

Eleven people a day.

Not exactly twiddling their thumbs, the HMRC staff, were they?  So where are those taxpayers – sorry, customers – sorry, people – going to go to for help now?

Posted in Bit of politics, HMRC | Tagged , , | 2 Comments »

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Closing the enquiry centres: the final response

May 24, 2013

Don’t forget that today is the last day to make your feelings known about the proposal to close HMRC’s face to face enquiry centres.  Here’s what I sent:

This is an individual response and is also published online, with commentary, on my blog http://tiintax.com.  There were four earlier blog posts on this issue which you might also find interesting to read.

1.  You have not included the question of *whether* contact centres should be closed within the scope of your consultation, presumably because the decision has already been taken.  However you say you will evaluate the “pilot” closure before proceeding further.  Given that the research on which your decision is based is only into the “always needs help” population (and does not include those of us who are “willing but need help” occasionally) I strongly suggest you include some customers in the group evaluating the pilot closure.  In particular, you ought to assess the impact on customers in your “willing and able” and “willing but needs help” categories as well as on the “always needs help” group.  You should do this by appointing an external scrutiny panel to work with you on the evaluation.  This should include trades union representatives and civil society groups from the affected area.
2. Here are the answers to your specific questions.  However you should note that your consultation document has some accessibility issues, for instance the inability to convert it to another format (e.g. at the simplest level, to copy and paste from it into an email) and is not in accordance with best practice.
Q1 Have we missed any particular groups in our definition of customers who need extra help?
This is a fundamentally misconceived question.  The enquiry centres support ALL of HMRC’s customers, not only those who need “extra” help.  Your proposals do not seem to allow for any service offering other than telephone and the web for anyone except “customers who need extra help” and so I suppose my answer is that the group you have missed is, everyone else!
Q2.  What do you think are the main benefits and disadvantages of the proposed new approach?
Clearly the main advantage is that you will “save” some £60 million a year in operating costs by closing the enquiry centres.  The main disadvantage is that you are diverting some £60 million a year away from customer service without any clear advantage in return.  The ordinary citizen has, surely, a right to a service from HMRC that enables them to pay their taxes efficiently.  Unless you can radically improve your basic service level offering over the phone and on the net, you are effectively taking £60m “savings” by putting the costs onto service users and civil society organisations.
The consultation also suggests to me that “ordinary” taxpayers are being offered a “take it or leave it” service and that the decision whether a person requires “extra” help will rest with HMRC rather than the service user.  This is deeply offensive – for example, I have a mild hearing impairment.  At present I can decide for myself whether I am able to transact with you over the phone or require further assistance either in person or otherwise.  Under your proposals it seems I will have to explain my impairment to a call centre operative and let THEM decide whether I’m disabled ENOUGH to be offered assistance.  I consider this is not only a “disadvantage” of your proposals but is likely to be in breach of your  statutory obligation to provide reasonable adjustment to citizens with disabilities.
Q3  Could any particular groups of customers find it difficult to contact HMRC using the new service?
Um… all of them?
Q4.  How do you suggest we can overcome any difficulties?
By treating taxpayers and service users as citizens with rights, rather than customers.
Q5  How else could we improve the proposed new service?
Ask the people affected at regular intervals.  Use citizen juries to check your conclusions.  Establish an oversight committee with representatives from civil society groups, trades unions and other affected parties to report back on progress.
Q6  What else could we do to improve:
(a) our new extra support telephone adviser service
(b) direction of certain customers to the voluntary sector and vice versa
(c ) the flexibility of our approach to providing support for those customers who need it?
A – see A5, above
B and C – these seem to me to be fundamentally misconceived questions.  HMRC should not be abandoning customers by telling them to eff off and talk to a charity – you have a duty of care towards all the citizens who transact with you, and “flexibility” is not, in and of itself, a positive to which you should aspire.  What you should be aspiring to is a satisfactory service (or, preferably, a better than satisfactory, i.e. a GOOD service) to ALL citizens of the uk.
Q7  Are there any other factors we need to take into account when trying to identify people who need extra help?
It is not your place to “identify” people who need extra help: people should be able to access help according to their own assessment of their needs, and you should be meeting those needs in accordance with the concept of all citizens having equal rights.
Q8.  Is there anything more we need to do to make sure that customers who currently use our Enquiry Centres, but don’t need extra help to resolve their query, can access our services?
You need to make substantial improvements to both your web and telephone offerings.  You might try a number of approaches, including but not limited to:
  • using citizen juries and other feedback mechanisms to improve your web presence
  • using basic feedback forms to capture feedback from users of the website in order to improve it
  • responding to enquiries submitted via email, twitter and other social media platforms and aggregating any frequently asked questions to create a dynamic feedback loop to improve your website
  • experiment with actually answering your phones (rather than filtering calls via recorded message trees)
  • take note of the research with clearly indicates that people dislike multilayered menus and voice recognition systems and increase the number of actual human beings responding to calls
Q9.  Are there any impacts on particular groups of customers that we have not identified and that need to be addressed?
Yes: people who need one-off help do not appear to be well served by the suggested new service.
Q10 How do you suggest we can overcome these?
See 8, above.
Q11.  Are there any other groups of customers that we have not included in our considerations.  If so, please specify who they are and let us know what we need to take into account in respect of these groups.
See 9 above.
Q12.  What other methods of communicating the consultation response should we be considering?
Seriously?  You’re going to close down the face to face service and you’re asking us how we prefer you to tell us?  How about “in a hundred years time”?

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h1

Um… hello?

May 10, 2013

efficient secondary legislation and engagement with the public through the medium of consultation is, in my view, the very bedrock of an effective and inclusive parliamentary democracy.  (The Earl of Lytton, Hansard  11 March 2013 Column GC34)

 

Maybe I’ve just lost my google-fu, my ability to find stuff on the internet? I don’t know.  I’ve been busy with the day job (I’m a PhD student by day and a writer of science fiction and fantasy by night) so maybe I’ve taken my eye off the ball.  But it occurred to me lately that, as well as finishing off my responses to the consultation on closure of the HMRC enquiry centres (the consultation closes on 24th May and I’ve already blogged about it here, here and here.  Oh, and here.  Not to mention here.) I should also check out what other tax consultations are around and plan what work I’m going to do on this blog over the next few weeks and months.

Um… hello?

So there doesn’t seem to be a tax tracker on the HMT pages any more.  The Treasury has moved all its consultations over to the new GOV.UK website, and the links on the Treasury site now take you to the consultations search page on GOV.UK, here.

Which might be helpful, except that, at the time of writing, there are 991 documents under the “consultations” heading on that page, they include open consultations, closed consultations, and consultation responses (and there’s no way to filter by “open consultations”).  Oh, and they’re in date order – of the date they were published and not by the date which would actually be useful, ie the date that the consultation closes.  (Has anyone told the Secondary Legislation Scrutiny Committee? (see para 54 here))

Filtering this with “tax and revenue” as the topic brings up five documents, the enquiry centre closure consultation and four closed consultations.

Well OK then.  Filtering it again by department, brings up 87 documents under HMT, only three of which are open consultations. (Two on finance industry topics, the “special administration regime for payment and settlement systems”, and one on “opening up UK payments” which I may go back to, because from a cursory glance it looks to be about abolishing cheques) and – finally – a relevant one, yet another tweak to the REITs regime, the rules on Real Estate Investment Trusts.

Filtering it by department again but this time scrolling down to find HMRC brings up fifteen results.  Only one of those is an open consultation, and it’s our old friend “Supporting Customers Who Need Extra Help: A New Approach”, which is newspeak for “Closing the Enquiry Centres”

But look back at this time last year.  In April and May 2012 I was responding to a dozen open consultations resulting from Budget announcements and pointing out that there were no fewer than 21 formal consultations which were listed on the tracker as being due to open in May.

So where are the 2013 consultations?  Were there no tax changes announced in the 2013 Budget?  (They weren’t all consulted on in a fortnight via twitter while I wasn’t looking, were they???)

The HMRC Budget 2013 page says all consultations will be on the GOV.UK site.

So, um… hello?  Where are they?

 

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