Archive for the ‘HMRC’ Category

h1

Google’s “Minor Tax Deal”

January 23, 2016

For once the headline says it all: Google Strikes Minor Tax Deal with UK Authorities.  Essentially it seems that Google has announced they’ve reached a settlement with HMRC (the timing is interesting: who decided to put it into the news cycle today?) They appear to have closed a six year enquiry covering ten years of activity by agreeing to pay an extra £130 million.

So roughly £13m a year?  (Are there any amounts in there for interest and penalties, I wonder?)

The point is, the amount is trivial in comparison with Google’s sales in the UK.  It’s one of the issues Margaret Hodge’s PAC did a lot of work on: remember this?

To avoid UK corporation tax, Google relies on the deeply unconvincing argument that its sales to UK clients take place in Ireland, despite clear evidence that the vast majority of sales activity takes place in the UK.

There are two changes that, in my view, need to be made.  First of all, if what the PAC found was in fact the case, then there was actual evasion rather than avoidance involved.  If there was “clear evidence” of evasion then we should have been looking at “perp walks” and prosecutions, not at a financial settlement.  Presumably there wasn’t, or there would have been, right?  I mean, right??  I assume Google weren’t guilty of evasion but HMRC need to be careful of the perception that evaders can get away with it if they’re big enough.  A way out of that perception would be for HMRC to be more ambitious about prosecutions: where are the large cases that involve direct tax, rather than the “quick wins” from smuggled fags?

Secondly, there are the usual calls for tax to be “simplified” so that people pay their “fair share”.  Quite.  Except this usually also falls into the mire of the citizen stakeholder asking for simplicity and fairness, and the tax professional saying it’s not so simple, and what is fairness anyway.

I have a suggestion how to get around that.  Episode two of the The Town that Took On The Tax Authorities.  Give me a budget, a camera crew and a bunch of engaged small traders like the people of Crickhowell.  And let’s see what happens…

h1

Vision on

January 12, 2016

How did “making tax digital” become “quarterly tax returns“?

Seriously, prepopulating tax returns, making them like a digital bank account and doing away with the annual return deadline is a brilliant idea and a great ambition for a twenty-first century tax department.  So how come the Treasury select committee is writing to David Gauke asking for assurances it won’t be a cock up, and how come there’s a petition with more than a hundred thousand signatures (the Magic Number that gets it considered for Parliamentary debate) asking for the idea to be scrapped, before the consultation has even started?

Well, first of all, HMRC is utterly crap at communicating with the very smallest small businesses, as anyone who has listened to me banging on about the VATMOSS VATMESS over the last year will know.  The “stakeholder” model breaks down when there isn’t a “stakeholder” group to talk to, and the very smallest traders don’t join trade associations because even the Federation of Small Businesses costs more to join than the likely profits.

There’s an alternative (the Small Firms Impact Test, which again I’ve banged on about in this blog once in a while) but (a) it costs money and (b) the government abolished it in favour of a vague requirement which adds up more or less to “Think about small businesses.  Are you thinking?  Good.  You can stop now.”

Secondly, HMRC is acquiring a serious reputation for being crap at customer service.  They have closed down the customer contact centres, they are appalling at answering their phones, and they keep getting caught trying to “nudge” our behaviour (and no-one likes to know they’re being manipulated)  So when something new is announced – as it might be, the closure of the national network of tax offices – and any negative feedback is ignored, the belief grows that HMRC is unresponsive to the people it works for, the ordinary taxpaying citizen.

The announcement of the move to digital tax accounts was trailed as the “end of the tax return”.  It was a Budget announcement, one of those surprise moves that you wonder about.  Was the Chancellor sitting there the weekend before the Budget listening to his Malcolm Tucker going, no, this won’t do: there’s nothing hot here: bring me something sexy?  Or is there someone in the HMRC or HMT hierarchy with an actual vision of how tax is going to work in the future and did they get their plan shuffled to the top of the pile?

The point is, it’s a good idea and it just might work. But not without someone articulating the vision and getting the public on board.

What happened, here, to the stage one consultation?  Remember? The 2011 Tax Consultation Framework?  Has it been abolished or is there still a legitimate expectation that there will be “early and continuing engagement” starting with

Stage One: Setting out objectives and identifying options

What would I have done differently?  Announced the objective of making HMRC

more effective, more efficient and easier for taxpayers

and identifying options that included abolishing tax returns, providing prepopulated electronic tax accounts, and moving to a fully digital system.

And then I’d have asked the taxpayers.  A charm offensive with journalists, a few quid bunged to some academics to organise some citizen juries, a dozen HMRC broadcasters retasked to add speech-making to the WI and the Soroptimists and the Lions and all those other organisations that people listen to and where they talk about stuff.

You know.  Made a preliminary stage consultation where you could demonstrate you were actually living up to your own processes and listening to your “customers”; and so you might have half a chance of persuading them you were proposing a change for the better, for once.  Trust me, I’m from the tax office.  That ought to be a slogan.  And not a joke.

 

 

h1

A radical idea…

January 11, 2016

…but it just might work.  Next time, let’s try having a tax professional at the head of HMRC?

Bear with me.  Today we saw the announcement that Lin Homer – sorry, Dame Lin Homer – is to leave HMRC in April.  This explains the “lately” mention in the announcement of her honour:

Ms Linda Margaret HOMER, CB

Lately Chief Executive, HM Revenue and Customs. For public service particularly to Public Finance.

People had been speculating on that “lately” for a while, and now we know.  (And, incidentally, has anyone been able to get a reasonable response from HMRC’s Press Office lately?  They seem to have cut back on staff so far that you have to be from someone Really Really Important before they have the capacity to get back to you.)

Now, opinions may differ on Homer’s legacy.  In the current climate you could well argue that still *having* a department is enough of a victory for any public servant (every now and then some oddball tweets me that it’s outrageous that HMRC hasn’t got any commercial competition.  There’s a whole other blog entry on the biblical “tax collector” and why they were thought to be evil, being outsourced collectors who took a cut of as much as they could get away with screwing out of you…)  Yes, there is still an HMRC, it’s still staffed (mostly) by public servants, they still (mostly) get (sort of) reasonable-ish terms and conditions, considering, and they still do the best they can in a department which isn’t corrupt in a system which hasn’t (yet) developed a reputation for corruption.

Damning with faint praise?  Maybe.  It doesn’t look much, when you look at it from that point of view, but in the current climate she probably did a pretty good job.  It’s just… well, you know.  The management-speak when there was any kind of internal challenge (yes, the leadership and managing change section of the HMRC Staff Survey is worth another look – ouch!).  The combative appearances before select committees.  The usual government-speak of statistics in verb-free public-speaking sentence fragments.

Was she the right person, in the right job at the right time?  Well, hindsight is easy, but does anyone have a different and more to the point better candidate in mind?

The important thing is, what comes next.  Angela Knight is now head of the Office of Tax Simplification.  The next person to head HMRC needs to be, I’m afraid, everything Angela Knight is not.  They need – in my view, anyway – to be a tax professional, so that they can talk to the tax industry and to their own tax professionals and command respect.  They also need to have, or at any rate quickly to achieve, a high profile with the wider taxpaying public, the muggles, so that the dangerous view that “they’re all the same” doesn’t become embedded in the British tax administration.  And they need to be able to manage a department which, ten years ago, was created out of two different departments by the simple method of putting them all into one black box and letting the strongest survive.  After the Darwinian winnowing that resulted, HMRC’s management now needs to be conducted on a rational basis, by someone who understands that there may be “22 professions in HMRC” but it’s the results achieved by the tax profession on which they will, ultimately, be judged.

Do I have a candidate in mind?

Not a scooby, sorry!  And it was all going so well…

 

h1

Weasels

January 1, 2016

Happy New Year!  Before we leave 2015 behind us altogether, can we just cast our minds back for a moment to the Autumn Statement and Spending Review and how much fun we all had playing Buzzword Bingo?  There are some words and phrases (hard working families; back office, efficiency savings) that make me want to reach for Goering’s gun, mainly because they are weasel words and phrases.  “Hard working families” means “you: nice people who have jobs and vote for us, and not them: nasty people you’ve never met and who claim benefits”.  “Back office” means “people who we think we can get rid of without making any difference, because everyone else will have just work harder for no extra pay to do their own typing and make their own travel bookings”.  And of course “efficiency savings” mean “cuts”. Well, I think I’ve found another weasel.  Look here: the Civil Service blog about what the spending review means for the service.  Apparently we must “modernise”.  Sounds reasonable, doesn’t it?  Throw away the fountain pens and the carbon paper and get with the 21st century.  Who could argue with that? Well no, apparently what needs to be modernised is civil servants’ “terms and conditions, to bring them more into line with those in the private sector”.  Now, I don’t know about you, but I’ve never had a job where you take home less money in one year than you did the previous year.  But if I hadn’t left HMRC when I did, that would have happened.  The combination of flat pay and rising deductions means that many of my former colleagues are literally taking home less than they did last year. It’s hard to have sympathy for someone on a 50K salary, do I hear you say?  Well of course it is, if you’re going to work on the principle that no-one should have cake till everyone has bread.  Me, I think there are enough resources in the world for everyone to have bread AND roses, and if some people have neither that’s because of political decisions.  But, to put it mildly, you are hardly going to encourage your brightest and best to consider public service if that’s how you are going to treat them. There is a lot of talk about the “covenant” between the country and the armed forces.  And, at the risk of going into old git mode (I seriously found myself considering typing the phrase “in my day”) I was always led to believe there was a “covenant”, an agreement, perhaps not a written contract but a gentleman’s agreement, between the civil service and the government, and in particular between the Tax Inspector and the government. We want you – in effect, it said – to be the watchdog on people with substantial fortunes.  We won’t pay you silly money, but we’ll pay you a middle class salary and give you decent terms and conditions, and we’ll see you right with a decent pension at the end of your service.  You might make more money on the Other Side, but you’ll make Enough in public service and you’ll know you’re on the side of righteousness. What changed during my career?  The naked contempt of the privileged for the poor sap who thinks public service is more important than (or even as important as) making money. So now we can look forward to a future where there is no longer a local branch network of HMRC offices, but a few mega structures and a computerised system.  Rather in the way that my bank helpfully centralised by closing all but one of its branches in Sheffield, and then sacked all the staff in the one remaining branch and replaced them with a wall of machines. Why should we care?  I was trying to think of something hopeful to say – a traditional New Year’s Day message of, well, things will be different but it’ll be all right in the end.  After all Lin Homer shall have her Damehood “for public service particularly to Public Finance.” (page 5) and we shall all have a Personal Tax Account. But honestly, I can’t really think of anything hopeful to say, sorry.  After all, it’s a commonplace now in HMRC management that “there are 22 professions in HMRC, not just tax.”  So presumably once the last tax professional has given up the ghost and joined the other side HMRC as an entity can just … do something else?

h1

Nailed

December 11, 2015

They say that, if all you have is a hammer, everything looks like a nail.  Well, my particular “hammer” is regulatory impact assessment, particularly that contained in the TIINs for tax measures.  So when I was asked to comment on the draft CIS legislation here I naturally turned to the explanatory memorandum to see what it had to say about the TIIN.

This is what it says:

A Tax Information and Impact Note covering this instrument was published on 10 December 2014 and is available on the HMRC website at https://www.gov.uk/government/collections/ta x- inf ormat ion-a nd- impact-notes-t iins.

I’m not by any means a conspiracy theorist: I’ve worked in HMRC and seen what can go wrong with publication.  When I looked at this for the first time, on Wednesday night, I dropped a line to the HMRC contact and to their press office with a question and with a mild comment that I was surprised they had linked here, to the overarching list of ALL of HMRC’s TIINs, rather than here, to the actual TIIN for this measure.  You will see that someone has helpfully tried to remedy this since then, but for some reason the revision contains random spaces so isn’t a clickable link.

Nevertheless, if we look at the TIIN for “Improving the operation of the Construction Industry Scheme” published on 10 December 2014 (and there is only one listed) we can see that the impact on business reads as follows:

These proposals are expected to relieve some of the regulatory burden of the CIS scheme.

The following measures, nil returns, joint ventures and repayments are expected to have a negligible impact on businesses. The measures simplifying the qualifying conditions for gross payment status will Benefit companies and partnerships by increasing their cash-flow.

The main changes to the CIS will take place in 2016 and 2017 and it is anticipated that it will affect approximately 40,000 businesses. Approximately 5 per cent of sole-trader contractors (2000) may require additional support as legislation is introduced to make verification and online filing mandatory.

Estimates of the impact on businesses will be established and published once details of the measure have been finalised.

(my emphasis)

Now, my question to the responsible official and to the HMRC Press Office was, where are the revised estimates for the impact on business, as the measure, or at least this bit of it, is about as final as you can get, surely?

Impact assessments are an enterprise that ought to be at the heart of government – an explanation of the evidence that underlies a policy decision, made transparent for the citizen to see for themselves that the government is making good, rational decisions.  They are important in the making of delegated legislation like Statutory Instruments because no parliamentary time is devoted to the Instrument’s discussion.  SIs are passed or not as they stand, and the mechanisms around their production are supposed to ensure that all the relevant factors have been taken into account before they are put before Parliament to be rubber stamped.  The Explanatory Memorandum should tell us what is being done, why, and in what policy context, that equality and human rights have been considered, that there has been consultation with those affected and the impacts have been considered, with a special mention on those impacts on small businesses, and that there is appropriate guidance in place.  Parliament should be able to take it as read, that all that needs to be done, has been done.

What we have with this draft SI is a link to an impact assessment which promises an update, but what we don’t have is an update which supports the legislation.  I suspect that the problem is simply that the original TIIN was badly drafted and that the promise of further consideration of the impacts refers to the previous paragraph, the difficult bits about mandatory electronic filing that haven’t been legislated yet and not to the whole package, but that’s not actually what it says.

It depends on your point of view.  If I had still been working for HMRC then I would have told the official what I have said above, and asked that the TIIN was updated or else the original clarified, perhaps by a note in the EM.

If I were an MP, I would consider it insulting to be asked to rubber stamp something that wasn’t ready to be passed on the nod (and I might well be asking my researcher to talk to the HoC library about his entry in Wikipedia “The last time a draft statutory instrument subject to affirmative procedure was not approved by the House of Commons was on 12 November 1969 when the House rejected four draft Orders relating to parliamentary constituencies.”)

If I were a member of the Joint Committee on Statutory Instruments I might want to draw the attention of the House to this SI on ground ix: “any other ground which does not go to its merits or the policy behind it” i.e. that the impact assessment has not, as promised, been updated.

It’s a small thing, but it shows either a contempt for the Parliamentary process or – and much more likely – that HMRC’s staffing levels have, finally, reached breaking point.

h1

The sheep thing

November 27, 2015

Have a look in Hansard at the debate about the HMRC closures:

Chris Stephens

Many MPs and tax experts support the view that a visible and local HMRC presence is essential to maintaining ​confidence in the tax system. Does he not believe that the measures that have been announced by HMRC will open the way for more tax avoidance?

Mr Gauke
No, I do not. As I have made clear, the number of HMRC officers has been falling since its creation in 2005, including over the past five years, and we have seen the closure of inquiry centres, as has been touched on, but HMRC’s success in dealing with tax avoidance and evasion over that period has been marked and has improved. The truth is that HMRC deals with tax avoidance and evasion principally through sophisticated data analysis and by bringing together highly skilled people. The more that we can do of that, the bigger the difference we will make.

There are several issues raised by the prospective closure of HMRC’s network of offices, and it does no-one any favours if we braid them together and pretend they’re all one and the same.

First of all there’s the argument that “tax avoidance and evasion” are fought “principally through sophisticated data analysis”.  I have no recent practical experience of whether or not that’s true – the last time I looked at a set of accounts in anger, the dispute was over whether an inspector’s judgement was more effective than a “package” of data sent from a remote analysis unit.  At the time it wasn’t, but I strongly suspect the balance has swung the other way and this is the way most cases will be broken in the future, particularly the larger ones.

But that isn’t the same argument as this one: “Many MPs and tax experts support the view that a visible and local HMRC presence is essential to maintaining ​confidence in the tax system.”  A remote analysis unit can’t do that job.

It’s an oversimplification, but think of it this way.  HMRC exists to serve us, the taxpaying public, by bringing in the money which funds public services.  They do that to a large extend by administering the tax system so that we, the taxpaying public, can pay our taxes.  That sounds like tautology but in fact it’s a profound truth.  I want to pay my taxes.  I want to pay the right amount at the right time.  I want to do it with the least amount of contact with HMRC possible, but if I *do* need to speak to them, I want them to be there, where I can get at them, to be contactable, and to be courteous, authoritative and knowledgeable when I speak to them.  And – as a taxpayer – I want them to come down in righteous wrath on the people who don’t do that.

There are two constituencies to be served, in other words.  The avoiders and evaders might well best be tackled by specialist accounts factories in remote locations: the first time an evader needs to contact HMRC is when they knock on their door with a warrant.  The rest of us, however, need an entirely different kind of service: local, accessible, friendly, helpful.  Treat avoiders and evaders like regular taxpayers and you may “nudge” some of them into normalising their relationship with taxes and behaving like the regular taxpayers they’re being taken for.  Treat regular taxpayers like avoiders and evaders, however, and you risk them saying to themselves, well, may as well be hanged for a sheep as a lamb…

h1

Why closing down HMRC’s network won’t save money either

November 22, 2015

A correspondent draws my attention to another reason why closing down HMRC’s network offices to concentrate in 13 regional centres is a bad bad bad idea.  It may not save the money anyway.

As I already suggested, it seems unlikely that HMRC can achieve spectacular savings in rent by announcing its preferred locations and only *then* negotiating for new premises.  I know office space isn’t exactly at a premium outside of London but are there really modern buildings which can house thousands of staff to be had for the asking?  There are unlikely to be so many suitable premises in each location that HMRC can sit back and expect a reverse premium for their willingness to move in: is it not much more likely that landlords will have seen them coming and hold out for substantial rents, as high or higher than the sum of the small office spaces being given up?

My correspondent, however, also suggests it is worth a look at the costs and patterns of employment.  In Wales, Scotland and for much of England it seems there are jobs being moved from areas of high unemployment to areas of low unemployment.  The current prediction is that 90% of the affected staff can move with their jobs to the new locations.  However around 70% of HMRC’s staff are in junior grades and – my correspondent suggests – 70% of those junior grades are part-timers on fewer than 20 hours a week.  Junior staff who are in part time work tend to be mainly women, mainly because they have other responsibilities.  This is a demographic unlikely to be able to commute for an extra hour each way every day. It’s a plan put together by people in London, for whom and hour and a half commute each way is a regrettable fact of life if you want to live somewhere bigger than a rabbit hutch.  Outside of London, however, the work/life balance is different.

So how will that work out? If someone is offered a post in one of the new HMRC Regional Centres an accepts it, will HMRC have to pay the excess travel costs, at least for the first year or so, as is usual in the Civil Service?

If the office space is expensive and employment costs increase, then how will there be savings?

The only savings I can see come from, well, shafting the employees.  If someone refuses a transfer to an office an hour and a half away, will they then  be considered to have made themselves voluntarily unemployed?  With the civil service pay cap and the abolition of pay progression, any new employee taken on to replace them would be on the lowest point on the scale and likely to stay there.  So you exchange one employee on a decent salary and one person on jobseekers allowance for one new employee on a lower salary and one former employee on… nothing at all.  Ka ching?

h1

Why closing all* the HMRC offices is a bad, bad, bad idea

November 18, 2015

*all but 13

HMRC announced last Thursday that their “modernisation” programme now requires them to close all their “expensive, isolated and outdated offices” and bring their remaining staff together in 13 “regional centres”.

This is a bad idea for so many, many reasons.  Here are a few of them.

  • HMRC as a national network used to have a mix of people who worked locally (who would notice a new business starting up or a conspicuous show of unexplained wealth) and people who were moved around the country for promotion (so the standards of service were national).  In the new plan, whole swathes of the country will have no physical HMRC presence.
  • Regional centres where someone spends their whole career have the potential to develop into fiefdoms with their own customs and practices – a national system becomes a postcode lottery.
  • A national system with regular staff mobility has an in-built anti-corruption apparatus**. A static regional team will need another bureaucracy of inspection and quality standard-setting.
  • As the PCS points out, there was no public consultation or parliamentary discussion of the plans. HMRC is a non-ministerial department but that doesn’t mean it can behave like a private company and arrange its affairs to suit itself rather than the public it services.  Obviously we need a tax administration fit for a twenty first century tax system… but who decided this was it?

There are also a couple of missed opportunities in the announcement

  • “The new regional centres will bring our staff together in more modern and cost-effective buildings in areas with lower rents”  I spent the last two or three years of my HMRC career living in Sheffield and working in London.  Because 90% of what almost any HMRC employee does can be done on a computer, and the computer could be located anywhere.  If HMRC invested in a decent network of secure laptops they could let large numbers of their staff work from home: do staff need to be concentrated in accounts factories to do their jobs?
  • The locations have been announced.  The buildings to be used in each location … haven’t.  Good luck with negotiating those “lower rents”, then!

 

**see for example Christopher Hood The Art of the State (p162) on the “gaming machine model of organisational design in traditional tax bureaucracy”

h1

Oh no you didn’t!

November 12, 2015

I find the Sheffield Theatres website appallingly difficult to use: one of those annoying merchants who won’t sell you anything unless you have an “account” but won’t open you an account because it tells you there’s already one connected to your email address but won’t for love nor money let you log into it.  I wanted to buy some panto tickets and wound up sending a complaining email instead…

… and they responded by emailing back, then telephoning me and walking me through the transaction,  and explaining that their website will be completely revamped in January.

And that’s what customer service looks like!

HMRC’s customer service, on the other hand…

HMRC’s customer service, and particularly their call handling, is criticised in the latest PAC report.  As Meg Hillier, the chair, said:

“It beggars belief that, having made disappointing progress on tax evasion and avoidance, the taxman also seems incapable of running a satisfactory service for people trying to pay their fair share.”

I’m interested in how the call handling figures are put together: according to the latest quarterly figures I can find, HMRC answered 67.1% of calls although the Guardian reports there’s a March 2015 figure of 68.3%.

But look at the response.  There are 3000 more staff handling calls, or, more precisely:

In the summer, HM Revenue and Customs (HMRC) recruited 3,000 additional staff into customer facing teams. The recruitment process included bringing people in on contracts to work in the evenings and at weekends, thus building capacity to handle calls outside of normal working hours. (David Gauke, PQ)

So is that 3000 new people recruited into HMRC?  3000 full time jobs?  3000 FTEs (“full time equivalent”) posts i.e. it might be more bodies working fewer hours but adding up to 3000 x 37 hours a week?  Or was there some internal “recruitment” of staff from existing jobs within HMRC into “customer-facing teams”?  I can find some anecdotal mention of there having been “1600” jobs advertised, but that is from a website of students complaining about the slow pace of the recruitment process (reply 19 here).  It seems from a twitter conversation that it was likely new bodies – 2000 full time and 1000 fixed term appointments – but it’s a sad indictment of the current state of public discourse that the text of David Gauke’s answer sounds like weasel words rather than an actual attempt to answer the question asked.

Why do I think that?  And why should you care?

Well, Jolyon Maugham starts from the same PAC report (in his Waiting for Godot tax blog) and lays out a compelling case leading to the  startling conclusion that

HMRC set out to mislead you as to its success in tackling offshore tax evasion. Not lying – because the document does not explicitly state that those are charging decisions in relation to offshore evasion – but an attempt to mislead.

When something goes wrong – like the Sheffield Theatres website – or looks as if it might have gone wrong  (because in the end it turned out that it was just my having logged into the site with Facebook instead of with my email address that was causing the problem) the way to deal with it is to deal with it.  If HMRC have recruited 3000 new customer service staff but found their resource insufficient to prosecute offshore evasion then they should say so.  And we should be able to trust what they say means what it sounds like, without the need for careful parsing and double checking.  No-one expects them to be able to do everything.

But if they imply they have prosecuted numbers of tax evaders in the hundreds we should be able to resist the urge to say “oh no you didn’t” (it was eleven, and the hundreds of prosecutions included all kinds of other offences).  If we stop trusting the integrity of the tax authorities, we’re in a whole new space.

h1

State of play

September 16, 2015

So there are fourteen open consultations listed as relating to HMRC on the gov.uk website today.  If you filter instead for the “tax and revenue” policy area (all departments) the total comes up as 18 – four from the Treasury.  Query: why are some tax consultations badged from the Treasury and some from HMRC?  Answers on a postcard…

The first is a review of travel and subsistence rules.  It was published under the coalition government, in July 2014, but says that it closes at quarter to midnight on 1st May 2016.  I find this rather improbable, and I wish gov.uk would have a look at it.

You have until 30th September to respond on the taxation of performance linked rewards paid to asset managers, employment intermediaries and tax relief for travel and subsistence, ISA qualifying investments and crowd funding, and the IR35 discussion document

You need to get motoring to respond to the implementation of the Personal Savings Allowance and the deduction of income tax from interest in peer to peer lending which both close on 18th September.  The other handful all have closing dates in October.

But I could have read and perhaps responded to one of them in the time I’ve taken today trying to identify which one to prioritise.  Because apparently listing consultations with a visible closure date and/or in the order in which they close remains beyond the wit of a twenty first century government.  Or, as I said on Facebook yesterday, you’d almost imagine they didn’t want responses from Jo Public.