Dear Hive Mind
Is there anyone who would find a podcast of this blog at all useful/interesting please?
Or, to put it another way, is there anyone who might read this blog if they had the time but thinks they would find it easier to listen to a podcast of it on the train?
(the “just because I have the technology doesn’t necessarily mean it’s such a good idea to use it” post!)
If you follow me on twitter (@wendybradley) you’ll know that, as well as linking to things that I find interesting about tax and regulation, I also enjoy the random stuff you find there: the occasional tweet-along of a television programme, for example (like shouting at the television, only the television shouts back) and I can usually be found on twitter on Sunday mornings for the regular tweetalong to the Archers omnibus.
So when I read the response document to the consultation on the use of rebated fuel for gritting in rural areas my eye was arrested by the statement on page seven that
Respondents pointed out that some rural roads are too narrow, not only for purpose-built gritters, but also for tractors to grit and therefore smaller vehicles like quad bikes would be more suitable.
So now all I can see is this wild vision of Josh and Pip Archer on the quad bikes nicked from Bridge Farm doing a ton down the Felpersham bypass with a gritter hitched to the back of each…
Ahem.
Anyway, you may remember that I responded last year to a consultation on The Use of Rebated Fuel for Gritting In Rural Areas. I thought it was a good consultation – clear and well written, with a good impact assessment that actually made sense – but my main response was to question whether there was any need for actual legislation to achieve the worthy aim of not hassling people who use red diesel when they lay grit in snow conditions in areas not covered by council services.
The response document lists the 105 respondents, aside from the five members of the “general public”. (I’m assuming mine was categorised as a “general public” response.) But, frustratingly, the response document is entirely silent on the question I raised, of whether legislation is actually necessary in this instance.
Leaving that aside, we have a further consultation closing on 28th July on the wording of the relevant legislation. Irritatingly, the consultation is now called “Amendments to Schedule 1 to the Hydrocarbon Oil Duties Act 1979” but it’s clearly the same measure.
Well, after they did so well on the consultation itself, it’s a shame to see them fall down at the final hurdle. Because the legislation out for consultation is a draft statutory instrument.
Now, a statutory instrument is a bit of legislation that gets through on the nod – there are two kinds, the ones where Parliament has actually to say yes for it to go through, and the ones where it just goes through unless someone actually says no. Since Parliament doesn’t amend them but just accept or reject them, they’re supposed to go before Parliament with all the i’s dotted and t’s crossed – which includes having an explanatory memorandum which tells you things like what the legislation is trying to achieve, how much it will cost, and what kind of consultation happened to get to this point.
And the gritter on a quad bike legislation? Well, it has a note that says
A Tax Information and Impact Note covering this instrument will be published on the HMRC website at http://www.hmrc.gov.uk/thelibrary/tiins.htm.
Which might be enough to get it through a whipped House, but is neither use nor ornament for the rest of us. Poor show.
Here (under the cut) is what I sent:
There are twenty-three open consultations listed at gov.uk under “open consultations” and “HMRC”. And, yes, two cheers to gov.uk for introducing a way of separating out “open consultations” from “closed consultations” and “all consultations” at long last. Frustratingly, however, consultations are still listed in order of publication rather than the date which would actually be useful, the date on which they close!
Here, therefore, for your delight, delectation, and holiday planning, are links to all 23 in the order in which they close. However I have to add a caveat that I was about half way through compiling the list when I realised that a small number of the consultations had ancillary documents (powerpoint slides, notes of meetings and other material) linked from the same part of gov.uk but at that point it was clear that compiling this list was going to take me all morning and I didn’t have time to go back and check which ones did and didn’t have ancillary documents. If you’re interested in a particular document, go check!
But kudos to the Gov.uk people for introducing an “open consultations” tab at last! Woo, and indeed hoo. But look at this page where they tell you there are, as of today’s date, one hundred and twelve open consultations across government.
Has anyone told the government they’re supposed to be cutting down on regulation, not going for the record?
I’m not sure I buy into binaries. There are two kinds of people in the world: those who think there are only two kinds of people in the world, and those who don’t.
Here’s a binary for you: either there is an unprecedented crisis which can only be solved by austerity politics, or there isn’t.
I don’t know which of these two states of being is true – I lean to the latter, but I could be wrong. But today, let’s pretend we believe otherwise. The government’s narrative is that we are in crisis, that the crisis isn’t of their doing, and that austerity measures are required to solve the crisis. The narrative is, indeed, that this course of action is succeeding: we are moving “from rescue to recovery”
So if that’s true, if austerity is the only way, then they are justified in freezing civil service salaries and reducing pensions. If that’s true, then they are justified in capping benefits and reviewing payments to people with disabilities and making people pay for their “spare” rooms.
If that’s true…
If that’s true, then MPs can’t have a pay rise.
If that’s true, then it doesn’t matter how much evidence they can adduce that their salaries are uncompetitive. It doesn’t matter how much evidence they can give us that they “ought to have” and “need to have” and “deserve” more. Because in the world where the government’s austerity narrative is true, that hasn’t mattered to anyone else.
Welcome to the real world, MPs. This is what austerity politics feels like from the sharp end.
There are only 10 kinds of people in the world: those who understand binary, and those who don’t.
“You take the blue pill, the story ends. You wake up in your bed and believe whatever you want to believe. You take the red pill, you stay in wonderland, and I show you how deep the rabbit hole goes.“―Morpheus to Neo, the Matrix
Dear MPs
Take the red pill.
No, you can’t have a pay rise. You’re public servants. Don’t you know that your own policy is to “ensur[e] that public sector workers do not receive pay increases purely as a result of time in post”? That public sector pay doesn’t rise with inflation but is capped at no more than 1% of the TOTAL paybill? That no more than 25% of very senior staff may receive performance related pay? So you could – maybe – give up to a quarter of MPs a performance-related pay rise that didn’t amount to more than 1% of the total MP pay bill. There are 650 MPs and they get £66396. So 650 x 66396 x 1% = 431574 divided by a quarter of 650… you can have – maybe – £2656. Or at least 162 or 163 of you can.
Take the red pill.
You need to compete for your share of the prize – you don’t get two and a half grand for nothing, you know! You don’t have a performance agreement? Well you’d better get on and agree one. Because if a quarter of you are going to get prizes, and 65% of you are going to be assessed as “achieving”, then ten per cent of you are going to be assessed as “low” achievers (see paragraph 6) And, well, you know you were all about the recall of underperforming MPs? I think it’s only fair that the low achieving 10% should be recalled, now don’t you?
Take the red pill.
So what would be in your performance agreement? Well objectives need to be SMART – specific, measurable, achievable, relevant and time-bound. There’s no money, and the coalition comes to an end on 7 May 2015 . So that reduces our options a bit, but have no fear – what gets measured gets done, so let’s make sure we’re measuring you on the right scale. Let’s have between three and five objectives, the way individual civil servants do. They’ll probably be quite generic: you’ll have to fight amongst yourselves for who gets the bonus pot relating to each one.
Take the red pill.
Let’s start with housing. In the coalition’s Housing Strategy for England you pointed out that there were only 115,000 houses built in the year before you were elected, and that there were expected to be 232,000 new households a year. So my first SMART objective for you would be to build 232,000 new houses (or flats, or “dwellings”) each year. Stretching but achievable, right? I mean, you have a strategy already! After all, you started “nearly” 50,000 in 2012… oh.
Take the red pill.
How about unemployment? There isn’t really a simple metric for that, is there? I mean, there are people who are “economically inactive” but aren’t on jobseeker’s allowance… do we count that as a success or a failure? So let’s get real: how many jobs are there? Let’s see… 400,000 jobs and upwards of 2million people chasing them? So how about we set a target of, say, a 25% increase in vacancies. If you want to be eligible for a pay-rise, let’s see half a million vacancies, and let’s see the ratio of unemployed people to job vacancies fall substantially. And, shhh, don’t tell anyone, but if you achieved the first target and built some houses, why, you could probably employ some people to do that! Two objectives hit in one!
Take the red pill.
Where else do you need a reality check? What about food? The Trussell Trust has some 325 food banks and hopes to have one in every town. They spent about three quarters of a million on their charitable activities in the latest year they have. The House of Commons spent about £5.8 million providing food, apparently making a profit, but managing to be rather numb and vague about whether there was a subsidy in there somewhere. But how about making a performance indicator out of equalising the amount spent on food for the Commons and food for the commons?
Take the red pill. Get real. You can’t have a pay rise till you up your game.
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.
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.
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?
OK then – you have until midnight tomorrow (4th June) to reply to the government’s consultation on “transforming” legal aid. Basically, so far as I can see, they want to cut the cost by moving to a US “public defender” type arrangement, where you don’t get to choose a lawyer and have them paid for, you get appointed a lawyer and you like it or lump it. Oh, and you’re not allowed to change them. Ugh! Here’s what I sent:
This is an individual’s response to the consultation “Transforming Legal Aid: Delivering a more credible and efficient system”. It will also be published, with commentary, on my blog, http://tiintax.com.
1. General comments. The document is 157 pages long with 36 consultation questions attached and Chris Grayling describes the proposals set out in those pages as “bold but fair”. I query the “fairness” in asking people to absorb 157 pages of closely argued text with an “executive summary” which appears to summarise what the government would like to get out of the consultation, rather than being a summary of the actual content of the document.
2. The total savings projected from the change are £220 million a year. However the “savings” seem to me likely to undermine the fundamental principles of justice for a comparatively paltry sum (this on a day when the projected £100 million saving from the proposal to abolish pensioner winter fuel allowances are described as “not much more than one thousandth of the projected annual deficit in 2015.”) You do not appear to include a regulatory Impact Assessment with your proposals, summarising the cost/benefit analysis of making these changes. To me as an ordinary citizen, however, a saving of 0.2% of the projected deficit does not outweigh the possibility of being falsely imprisoned because of a mistaken accusation dealt with by a cut-price lawyer wanting me to plead guilty to keep down his costs.
3. When you are dealing with a subject which is key to the relationship between citizens and their government and as important as the criminal justice system the first question shouldn’t, surely, be about how to cut the costs by restricting the eligibility and scope of financial support but, rather, how to improve the system administratively to prevent vital services like criminal advocacy being cut. For example, there are administrative reforms which would greatly cut the costs of the legal system. I realise basic administrative competence isn’t a “sexy” subject likely to gain headlines, but making sure that prisoners are brought to the right court at the right time, that prosecutors have the right papers in front of them (and are in the right place at the right time) and that interpreters are available, competent and, again, in the right place would, surely, contribute greatly to the efficient administration of justice and are all matters where you could make substantial savings via administrative competence rather than by cutting services? Surely this is a proposal which would be actioned before any cuts to services are considered?
In answer to your specific questions:
1) Restricting the scope of legal aid for prison law
Q1. Do you agree with the proposal that criminal legal aid for prison law matters should be restricted to the proposed criteria? Please give reasons.
No. If a person in prison was dealing with public servants then I might be prepared to agree that their rights could be protected by recourse to a complaints and ombudsman system. However when someone has been deprived of their liberty and imprisoned in a privately-run prison where they become a profit-centre for an unaccountable company I think it is vital that they are able to access legal assistance.
2) Imposing a financial eligibility threshold in the Crown Court
Q2. Do you agree with the proposal to introduce a financial eligibility threshold on applications for legal aid in the Crown Court? Please give reasons.
No. See para 3.24 of the consultation! This basic “interest of justice” is not overturned by a temporary fiscal panic.
Q3. Do you agree that the proposed threshold is set an appropriate level? Please give reasons.
No. See answer 2 above.
3) Introducing a residence test
Q4. Do you agree with the proposed approach for limiting legal aid to those with a strong connection with the UK? Please give reasons.
No response
4) Paying for permission work in judicial review cases
Q5. Do you agree with the proposal that providers should only be paid for work carried out on an application for judicial review, including a request for reconsideration of the application at a hearing, the renewal hearing, or an onward permission appeal to the Court of Appeal, if permission is granted by the Court (but that reasonable disbursements should be payable in any event)? Please give reasons.
No. Judicial review is a vital way of enabling a citizen to challenge government overreaching its authority. There are already high financial barriers to pursuit of cases, and the fact that a proportion of cases were lost does not mean that arguing them was without merit. I would also like to see an impact assessment showing a cost/benefit analysis of this individual strand of the proposal – my suspicion is that it would not support the proposal.
5) Civil merits test – removing legal aid for borderline cases
Q6. Do you agree with the proposal that legal aid should be removed for all cases assessed as having “borderline” prospects of success? Please give reasons.
No. This takes the decision away from the courts – where such matters should be decided – into a quango having financial prospects as a major decision-making criterion.
Chapter Four: Introducing Competition in the Criminal Legal Aid Market
i) Scope of the new contract
Q7. Do you agree with the proposed scope of criminal legal aid services to be competed? Please give reasons.
No. Putting contracts out to tender does not favour “competition” – there is already competition, between small firms with specialist expertise in different types of law. What you are talking about with “tendering” is encouraging them to band together under the umbrella of a financing organisation and produce representation at the lowest possible cost with no consideration of value or quality. It is, frankly, an appalling idea.
Q8. Do you agree that, given the need to deliver further savings, a 17.5% reduction in the rates payable for those classes of work not determined by the price competition is reasonable? Please give reasons.
No! But please, if that’s a reasonable idea, let’s see all Members of Parliament receive a 17.5% reduction in their salaries and expenses and revert to the idea after three years of successful operation.
ii) Contract length
Q9. Do you agree with the proposal under the competition model that three years, with the possibility of extending the contract term by up to two further years and a provision for compensation in certain circumstances for early termination, is an appropriate length of contract? Please give reasons.
No response
iii) Geographical areas for the procurement and delivery of services
Q10. Do you agree with the proposal under the competition model that with the exception of London, Warwickshire/West Mercia and Avon and Somerset /Gloucestershire, procurement areas should be set by the current criminal justice system areas? Please give reasons.
No response
Q11. Do you agree with the proposal under the competition model to join the following criminal justice system areas: Warwickshire with West Mercia; and Gloucestershire with Avon and Somerset, to form two new procurement areas? Please give reasons.
No response
Q12. Do you agree with the proposal under the competition model that London should be divided into three procurement areas, aligned with the area boundaries used by the Crown Prosecution Service? Please give reasons.
No response
Q13. Do you agree with the proposal under the competition model that work tendered should be exclusively available to those who have won competitively tendered contracts within the applicable procurement areas? Please give reasons.
No response
iv) Number of contracts
Q14. Do you agree with the proposal under the competition model to vary the number of contracts in each procurement area? Please give reasons.
No response
Q15. Do you agree with the factors that we propose to take into consideration and are there any other factors that should to be taken into consideration in determining the appropriate number of contracts in each procurement area under the competition model? Please give reasons.
No response
vi) Contract value
Q16. Do you agree with the proposal under the competition model that work would be shared equally between providers in each procurement area? Please give reasons.
No response
vii) Client choice
Q17. Do you agree with the proposal under the competition model that clients would generally have no choice in the representative allocated to them at the outset? Please give reasons.
Absolutely not! It is an inquitous idea, that a citizen will be prosecuted by the state and defended by a cheapskate state-appointed lucky-dip lawyer with no right to choice!
viii) Case allocation
Q18. Which of the following police station case allocation methods should feature in the competition model? Please give reasons.
Option 1(a) – cases allocated on a case by case basis Option 1(b) – cases allocated based on the client’s day of month of birth Option 1(c) – cases allocated based on the client’s surname initial Option 2 – cases allocated to the provider on duty Other
This is an appalling idea, but if (as I suspect) you go ahead with it anyway, then at least let the person allocated be random. So a duty rota system is preferable to one based on surname, and a day or month of birth option preferable to either – neither the police (by arresting someone when a firm perceived to be less competent was on duty) nor a provider (by avoiding taking surnames beginning with a particular letter because of a perceived racial bias) should be able to game the system, so far as it can be prevented.
Q19. Do you agree with the proposal under the competition model that for clients who cannot be represented by one of the contracted providers in the procurement area (for a reason agreed by the Legal Aid Agency or the Court), the client should be allocated to the next available nearest provider in a different procurement area? Please give reasons.
No response – I think I lost the will to live around this point in the condoc
Q20. Do you agree with the proposal under the competition model that clients would be required to stay with their allocated provider for the duration of the case, subject to exceptional circumstances? Please give reasons.
Good god, no! No matter how hostile, unhelpful, incompetent or just plain uninterested your state-appointed lawyer might be, you’d have to stick with them whatever? No!
ix) Remuneration
Q21. Do you agree with the following proposed remuneration mechanism under the competition model? Please give reasons.
Block payment for all police station attendance work per provider per procurement area based on the historical volume in area and the bid price
Fixed fee per provider per procurement area based on their bid price for magistrates’ court representation
Fixed fee per provider per procurement area based on their bid price for Crown Court litigation (for cases where the pages of prosecution evidence does not exceed 500)
Current graduated fee scheme for Crown Court litigation (for cases where the pages of prosecution evidence exceed 500 only) but at discounted rates as proposed by each provider in the procurement area
No response
Q22. Do you agree with the proposal under the competition model that applicants be required to include the cost of any travel and subsistence disbursements under each fixed fee and the graduated fee when submitting their bids? Please give reasons.
No response
x) Procurement process
Q23. Are there any other factors to be taken into consideration in designing the technical criteria for the Pre Qualification Questionnaire stage of the tendering process under the competition model? Please give reasons.
No response
Q24. Are there any other factors to be taken into consideration in designing the criteria against which to test the Delivery Plan submitted by applicants in response to the Invitation to Tender under the competition model? Please give reasons.
No response
Q25. Do you agree with the proposal under the competition model to impose a price cap for each fixed fee and graduated fee and to ask applicants to bid a price for each fixed fee and a discount on the graduated fee below the relevant price cap? Please give reasons.
No. How can you put a price on justice, before you even know what’s involved? What if you need expert witnesses, what if you need to bring in outside expertise. A price cap is an appalling idea.
Chapter Five: Reforming Fees in Criminal Legal Aid
1) Restructuring the Advocates’ Graduated Fee Scheme
Q26. Do you agree with the proposals to amend the Advocates’ Graduated Fee Scheme to:
introduce a single harmonised basic fee, payable in all cases (other than those that attract a fixed fee), based on the current basic fee for a cracked trial;
No response
reduce the initial daily attendance fee for trials by between approximately 20 and 30%;
How on earth do you justify reducing fees by 20-30%? What possible basis is there for this – are your figures plucked out of the air? Please see response to question 8 and come back to me when MPs have done it themselves for three or four years and
taper rates so that a decreased fee would be payable for every additional day of trial?
Actually, you got me. That’s one that I actually think is in principle a reasonable idea. Well done you.
Please give reasons. Because once the research is done and the case is prepared, the actual number of days involved doesn’t add value… although of course conversely if the length of the trial is down to administrative incompetence on the part of the prosecution, then logically the fees should INCREASE rather than decrease, so as to discourage prosecutors from trying to game the system.
2) Reducing litigator and advocate fees in Very High Cost Cases (Crime)
Q27. Do you agree that Very High Cost Case (Crime) fees should be reduced by 30%? Please give reasons.
See response to question 26 point 2
Q28. Do you agree that the reduction should be applied to future work under current contracts as well as future contracts? Please give reasons.
No! Good grief, are you really saying there’s a 20-30% layer of fat in current pricing of legal work? Because I find that a bit improbable.
3) Reducing the use of multiple advocates
Q29. Do you agree with the proposals:
to tighten the current criteria which inform the decision on allowing the use of multiple advocates;
No. There’s a basic fairness requirement. If the prosecution has two or three advocates, then the defence should be funded to a similar level.
to develop a clearer requirement in the new litigation contracts that the litigation team must provide appropriate support to advocates in the Crown Court; and
to take steps to ensure that they are applied more consistently and robustly in all cases by the Presiding Judges?
Please give reasons.
No: surely the state has all of the cards here. If we’re saying the citizen on the other side has to play by a set of cards dealt to them by the state, at least give them the same number from the same deck! Your proposals send the individual into a high stakes poker game with monopoly money.
Chapter Six: Reforming Fees in Civil Legal Aid
1) Reducing the fixed representation fees paid to solicitors in family cases covered by the Care Proceedings Graduated Fee Scheme:
Q30. Do you agree with the proposal that the public family law representation fee should be reduced by 10%? Please give reasons.
See question 8. No!
2) Harmonising fees paid to self-employed barristers with those paid to other advocates appearing in civil (non-family) proceedings
Q31. Do you agree with the proposal that fees for self-employed barristers appearing in civil (non-family) proceedings in the County Court and High Court should be harmonised with those for other advocates appearing in those courts. Please give reasons.
No: barristers get different fees for a reason (not least because they’re self employed businesses in their own right.)
3) Removing the uplift in the rate paid for immigration and asylum Upper Tribunal cases
Q32. Do you agree with the proposal that the higher legal aid civil fee rate, incorporating a 35% uplift payable in immigration and asylum Upper Tribunal appeals, should be abolished? Please give reasons.
No response
Chapter Seven: Expert Fees in Civil, Family, and Criminal Proceedings
Q33. Do you agree with the proposal that fees paid to experts should be reduced by 20%? Please give reasons.
No: see response to question 8
Chapter Eight: Equalities Impact
Q34. Do you agree that we have correctly identified the range of impacts under the proposals set out in this consultation paper? Please give reasons.
You have failed to consider the possibility of a person being allocated a lawyer who is of a different gender, ethnicity or other protected characteristic from their own and of the effect the lack of choice and lack of ability to change might have on the client/provider relationship. In very simple terms, if you are a woman and are allocated a misogynistic solicitor, tough!
Q35. Do you agree that we have correctly identified the extent of impacts under these proposals? Please give reasons.
As above. You do not appear to have considered the intangible elements – trust, support, confidence – vital to the relationship. A take-it-or-leave-it, no choice, no change service will leave people with a much lower degree of confidence that they are being treated fairly.
Q36. Are there forms of mitigation in relation to impacts that we have not considered?
An ability to exercise choice of advocate should be included in the proposals. If necessary you could prevent people “gaming” the system by allowing one change without reasons being given and a second change (perhaps at judges’ discretion) if a reason was put forward.
Regards
Wendy Bradley
http://tiintax.con
Here are the four from HMRC:
| Title | Link | Date of closure |
| Changes to VAT zero-rating of exports from the UK | Link here | 5 July 2013 |
| National insurance and self-employed entertainers | Link here | 6 August 2013 |
| A review of two aspects of the tax rules on Partnerships | Link here | 9 August 2013 |
| Office of Tax Simplification: review of unapproved share schemes | Link here | 16 August 2013 |
(One day I’ll work out how to do pretty tables in WordPress, sorry!)
There are a couple of interesting things about this list, over and above my general gripes about the problems of finding them in the first place.
Note the closing dates? The earliest one is 37 days away, and the others are 69, 72 and 79 days respectively. The days of a three month (90 day) consultation are over, and the concern about consultations over holiday periods haven’t quite sunk in yet.
Also… where are the rest? Look at table 2.1 (starting on page 64 here) of Budget Policy Decisions. Ignore the measures already announced and skip down to the heading “Growth and enterprise” and look from there to the end of the table. I make it 29 measures from there on down which are categorised as “tax” (as opposed to spending) changes. Then look at OOTLAR (Overview of Tax Legislation and Rates) published at the same time and go to chapter two, Future Tax Changes (start on page 18) where you will find 47 announcements, some of which will and some of which won’t lead to consultations.
Oh, and look at this, published in the same chapter, back in March:
2.1 This chapter summarises new tax changes announced in Budget 2013, where the change is to be made in Finance Bill 2014, other future finance bills, programme bills or secondary legislation. In line with the Government’s new approach to tax policy making, the vast majority of these measures will be subject to consultation. To assist those who wish to take part in tax consultations, a “tracker” will be published on the HM Treasury and HMRC websites setting out the planned dates of future consultations.
Well where’s my bloody tracker then????
tiintax 