Posts Tagged ‘business’

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Language, Timothy!

March 4, 2013

Back to the Mail Online again today for the story about the top dozen UK companies that pay no tax.  Serendipitously, there’s some thoughtful material on the same subject from Robert Maas in the last issue of Taxation (behind a paywall, sorry) where he asks “Are organisations really dodging tax, or are they just following the rules?”

This brings me back to the language of tax; Maas makes some reasonable points

  • Amazon makes its UK sales through a Luxembourg subsidiary.  It has warehousing in the UK, but under the 1968 Double Taxation agreement with Luxembourg a warehouse doesn’t constitute a “permanent establishment” that would make the sales from that warehouse taxable in the UK.
  • Starbucks has its intellectual property in a Netherlands company (in other words the know-how of how to run a branch of Starbucks) and it franchises UK shops.  So the profits made by an individual franchise would be payable by the franchisee in the UK, but would be decreased by the amount it pays to Holland for the know-how.

but his conclusion – “Most of the so-called avoidance schemes that are being publicly criticised are not avoidance at all” is a bit more difficult if you’re not a tax expert.

The fact is that the person on the Clapham omnibus – the tax muggle, if you will – doesn’t care about the complexity of tax legislation but applies the “it’s not fair” test.  It doesn’t feel fair that I have spent £100 on books without leaving my chair and that a British postman has brought them right to my door, but because I bought them from Amazon instead of [insert name of non-Amazon book seller here.  There must still be one somewhere, right?] then the profits the seller made aren’t taxed here but in Luxembourg.

Similarly it feels wrong if I’m sitting in Sheffield drinking a caramel macchiatto and eating my red velvet cake but somehow the profits from selling them to me get taxed in Holland.

But if we talk about tax avoidance in these terms it seems to me we’re generating heat without light.  “It’s not the firms, it’s the system” yes, maybe – but where does that get us?  The interesting thing to me is the government’s ambition to make the UK a “competitive” tax system, to show that it’s “open for business”.  That’s where I can shrug and agree with Maas that it’s not necessarily a “fault” for a company to arrange its trade in a way that takes advantage of the “competitiveness” of the different tax regimes in different countries: the issue isn’t with the actions of the company but with the people who designed the system in which they operate.

Perhaps, though, the issue takes us back to the one which didn’t really get bottomed out in the PAC hearings – if the fault is in the way the government makes its tax legislation, then the whiff of something smelly comes from the involvement of the same big businesses that profit from “tax competitiveness” in designing the competing systems.  That’s why we shouldn’t have a revolving door between industry and civil service, and why we should have records of meetings between Ministers and civil servants and industry representatives.

And, while we’re at it, why we ought to have the Small Firms Impact Test back in the list of things that must be included in the work of policy development, rather than archived at the back of the bus and replaced by some meaningless warm words.

Posted in Bit of politics, Consultation, SFIT | Tagged , , , | 1 Comment »

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It’s academic

September 18, 2012

Next week I’ll be starting a PhD at the Law Department of the University of Sheffield.  My current topic title is Tax Simplification and Better Regulation, and so the question of what is an academic and how we recognise and reward academics is one which I expect will be increasingly close to my heart.

So, full disclosure made, let’s now turn to the consultation on Enterprise Management Incentives: Extending Access for Academic Employees.  Woo hoo!

OK, well the government is quite clear it doesn’t want any of your faffy-abouty dissertations around the subject.

1.15 The Government is not seeking views during this consultation on broader issues, such as:

 whether there are employees other than academics for whom the present EMI working time requirement should be relaxed;

 the limits that apply to the value of EMI options that may be held by an employee or granted by a company;

 the requirement that EMI options may only be issued to employees of a qualifying company or group; or

 the features or requirements of any tax advantaged employee share scheme other than EMI.

So there! “This consultation is only concerned with the limited issue of allowing access to EMI for certain academic employees who do not currently meet the working time requirement.”

Basically what it seems to be about is a scheme to let small companies attract and retain talent by awarding shares to their employees without having to pay tax and national insurance on them.

EMI is a popular and successful scheme which each year enables around 20,000 employees to obtain options over shares with a total value of around £250 million, and provides tax advantages on exercise of these options of around £200 million.

But – to prevent the scheme being used as an avoidance device – there are rules to ensure your employee is an actual employee (and not a potential tax avoiding investor who “works” for you for half an hour a month at the minimum wage).  And these rules seem to mean that academics who do work for this kind of company sometimes come up against problems because of course their contract with their academic institution will usually mean most of their time is already spoken for.

You can see the point.  What we want is for scientists to take their brilliant ideas and turn them into brilliant businesses as well.  So let’s not faff about: give them the relief.  Agreed?  Good.

All right then.

So why are we doing it by way of a formal written consultation?  Why aren’t we doing it under the HMRC “care and management” powers – simply tell HMRC staff to stop faffing about trying to find ways that an academic working for an EMI scheme might NOT qualify.

Or why aren’t we setting up an expert working party with some actual academics who are or have been involved in EMI schemes to thrash out the definitions, like we’re doing with the creative industries consultation I wrote about yesterday?

Why haven’t we got any idea of the scale of the problem being addressed  – the impact assessment says helpfully that:

This measure is expected to have a cost, the magnitude of which will depend on the outcome of this consultation.

Why haven’t we got anyone in HMRC or HMT who looks at these documents before they go out and says “look, Fred, Freda, I see what you’re getting at, but have you seen what they’re doing in the Creative Industries team?  Couldn’t you try something like that?”

So this is another consultation I don’t propose to respond to.  Because when your first question is

Can you provide details and evidence on the typical working patterns and arrangements of academic employees engaged by EMI qualifying companies – for example, whether this involves a regular and permanent weekly commitment of time, or whether working time is concentrated at particular times of the academic year?

wouldn’t it occur to you that there are people who would know?  And wouldn’t it be a good idea to ask them?

How much does it cost to do a formal consultation, do you think?

Posted in Consultation | Tagged , , | 1 Comment »

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RTI is coming. Eep!

September 6, 2012

You may remember that, in 2010, the idea was floated that we should update the pay as you earn system.  Why should employers have to calculate how much tax to deduct from wages and salaries?  Wouldn’t it be neat if you could build some kind of machine – or, OK, some kind of app – that would work it out?  Plug that into the banks, and the employer could just transfer your whole salary to you and the bank could siphon off the bits of that money that go to HMRC using the magic machine/app.

The newspapers put paid to that one pretty quickly!  And, frankly, would you trust

  1. government IT procurement and/or
  2. banks

as far as you could throw them?

So, er, no.  Or indeed “hell no!”  But the PAYE system was still in dire need of updating – so then there was RTI.

RTI, for the uninitiated, stands for “real time information” – the “minor” change to PAYE that means employers will have to tell HMRC what they’ve paid when they pay it (and not six months or a year later).

Oh, and there’s an administrative burden “saving” to employers, because they won’t have to fill in P60s and P45s at the end of the year or when people change jobs any more; all the information will go seamlessly to HMRC when the salary payment is made.

Which, if you’re an employer with a payroll that’s computerised and a who pays via the bank, well, might actually be true.  The impact assessment thought there might be a billion quidsworth of savings.  Particularly if you don’t, er, quantify any costs!

RTI is, in fact, already here – for the small number of employers taking part in a pilot scheme.  And more employers are being added – did you know that?  And ALL employers will (or at least should) be in RTI by autumn of next year.

OK.  So far, so good.

But there’s a certain amount of, what we might politely call, “making it up as you go” involved here.  Taxation magazine pointed out on 22 August  (sorry, it’s behind a paywall) that there will be problems involved in paying

  • Casual workers
  • People receiving tips via a tronc

and various other special cases, because the RTI return has to be made at or before the time of payment.

So it’s Saturday night and you’re a pub landlady and your barmaid just called in sick and you call the two students who work odd shifts for you on standby.  They’re going to expect their wages in their hand when they go home at the end of their shifts, aren’t they?  So are you going to spend your night filling in their RTI details on your laptop so you can make them a legal payment… or are you going to go cash in hand and take your chances?

So you’re a restaurant and the tips go into a jar and the head waiter divvies them up on a Saturday night.  Is he really going to sit down and enter all the details of the payees into his laptop before he goes home?

But more worrying to me is the abolition of the Simplified Deduction scheme, which was known as the “nanny” scheme – a simpler set of deduction instructions for people who found themselves employers but who weren’t actually businesses, like people who directly employ a nanny or a cleaner (rather than paying them via an agency).  This one worries me a lot, particularly because of trend in providing services to people with special needs because of age or disability by giving them a budget and asking them to arrange their own services.  These are not people who will be immediately comfortable with running a PAYE scheme to pay for the carer who gets them out of bed in the morning.  In the equality section of the RTI TIIN published in March this year it said:

Care and support employers are individuals who employ carers to provide services to a disabled or elderly person in their home. This group of employers will join RTI from April 2013 and HMRC will offer them the option of monthly paper filing of information. They will also be able to use HMRC’s free updated Basic PAYE Tools which are available for all employers who employ nine or fewer employees, allowing them to submit RTI via the internet. HMRC has also provided funding to the Low Incomes Tax Reform Group (LITRG), to help them develop online guidance for care and support employers.

which, frankly, looks to me like an enormous exercise in Missing The Point Entirely!

In this context then you can see that I might not be too fussed about a consultation document that is concerned with penalties to be imposed for failure to comply with RTI.  In my view it’s absurdly premature to talk about penalties for failure to comply with a scheme that you’re making up as you go along.  Introduce it, work out the kinks, give it a couple of years to see what the compliance rate looks like… and THEN see what sanctions you need for the few who play fast and loose with the system.

Nevertheless, that isn’t the question being asked.  But here’s what I said in reply.

This is an individual’s response and will also be published, with commentary, on my blog, http://tiintax.com. I have followed the question schedule set out on page 35 of the consultation document.

Q1. Do you have any comments on RTI and error penalties that will help us support businesses and promote timely filing under RTI?

I think it is wholly premature to be talking about penalties at this stage in the process, when there are enormous outstanding questions about how the scheme will operate at the margins. At the moment HMRC should be concentrating its resources on “support” rather than punishment. “Care and support” employers, in particular, should be exempt from penalties except in cases where a criminal penalty could be sought – in other words where the department can produce evidence of deliberate default rather than failure to understand and apply the system.

Q2. How best can we support employers in understanding their obligations under RTI and implementing the new system?

Not via penalties! An advertising campaign, dedicated support teams, face to face training and assistance – all the kind of support services that HMRC used to be able to provide via its local office network, its employer support teams and its advertising and comms team. Otherwise there’s a serious risk that micro employers will move to cash in hand payment by default.

Q3. Is there a better or simpler way, than banding by potential filing defaults, of recognising the size of the employer but also the amount and regularity of the information to be supplied under RTI?

I would make an exception for cash payments of less than £X, where X is something like the minimum wage x say 5 days and the employer is a micro business. So the pub paying its casual staff on a Saturday night has a couple of days grace to get the RTI return made without being hit with an automatic penalty (but would still be hit if the RTI information isn’t provided within say a week) – so the crisis can be covered and RTI dealt with as part of the normal working week even if it is a couple of days behind.

Q4. Are there particular adjustments that should be considered to take account of more frequent payments?

It depends really on whether your aim is to make everyone move to electronic submission and payment. Someone who is reporting on paper should be allowed to make monthly returns – but presumably you won’t want large employers to make paper returns mischievously. So this is as clear a case as I can envisage of a case where the government’s own policy to exempt micro businesses should be followed.

Q5. Should a penalty be charged as soon as a return is late or would employers prefer penalties to be charged later, perhaps each quarter?

Um – “prefer”????? What are we talking about here? If we’re working in a world where you ask people how they “prefer” to pay penalties, isn’t there some kind of presumption that penalties will be routine? And yet I thought it was clear HMRC policy that penalties would be just that – they would be PENAL – and only apply to people actively subverting or avoiding the system, not to people confused by the system or making an honest mistake?

In which case this is a nul question. You don’t get a choice about a penalty! But my preference, in my capacity as a citizen stakeholder, would be for defaulters to be charged penalties as soon as the return was late – if it’s genuinely aimed at getting them back on the right track then they need to know straight away that their actions have consequences.

Q6. Do you agree that only one late filing penalty should apply to each PAYE scheme each month, regardless of how many returns are late that month?

Yes

Q7. Should the RTI late filing penalties include a further penalty if a return is outstanding at the 6 and 12 month points?

No. You ought to be well beyond late return penalties and into corrective action by HMRC at those points.

Q8. What are the benefits and downsides of phasing the introduction of automatic late filing penalties for RTI along the lines set out above?

It’s absolutely vital that late penalties are only applied to the very largest employers and in the case of deliberate default first, and then phased in by size of payroll, not reaching the micro business employer until the system is fully mature. And arguably never reaching the “care and support” employer at all.

Q9. Should consideration be given to including a default that does not attract a penalty along any of the lines set out above?

No. A “default that does not attract a penalty” needs to exist in the system, but this is a case where HMRC shouldn’t be judge and jury but should be required to charge a penalty via a tribunal process rather than automatically. So I would exclude micro businesses from any automatic penalty regime while leaving the option of HMRC taking offensive cases via the tribunal system.

Q10. We would be grateful for comments on the detailed design options set out above. In particular, how should we encourage employers to use the nil return facility where there is no information to be returned? Is any additional incentive or sanction needed over and above the fact that a late filing penalty may be issued if an expected return is not received?

This baffles me, I’m afraid! If RTI is predicated on a return being made whenever a payment is made, how would HMRC know that any payment had been made in a “pay period”? What IS a “pay period” for these purposes?

Example: I’m thinking of taking on a casual employee to do work on my garden. I’d think about taking on a student and employing them as-and-when I have work available. So I might pay them a tenner every week for an hour’s work in the summer, but once every six weeks in winter – but then a one-off £50 when I needed some help lifting and carrying. What would be my “pay period” – or are you assuming that this kind of casual arrangement would be “cash in hand” and not touch the sides of RTI in 99% of cases?

Q11. What are the pros and cons of charging penalties for late filing and late payment at the same time?

It’s one of my pet peeves about the tax system that the two aren’t linked – it’s absolutely no use to anyone to establish a requirement to pay £x, a penalty of £y for not returning the requirement to pay £x… and then never bothering to collect either of them!

Q12. We would be grateful for comments on these models, or any combination of the elements included in the models. We would especially welcome ideas to simplify them, but which still support and encourage compliance with the RTI information obligation.

See comments above on the need to exclude micro businesses. In accordance with the government’s stated policy on the small firms, micro businesses should be exempt from regulatory change unless there’s a really good reason not to.

Q13. We welcome comments on these proposals. (This refers to the changes to the existing late payment penalty model).

It would be in keeping with what I understand of the RTI proposals, as well as a welcome simplification for everyone, if late return and late payment penalties were merged. Why doesn’t the submission of a return also trigger the submission of a payment? Employers should no longer be able to use their PAYE scheme as a cash flow tool. It’s not their money – it’s their employees’.

Q14. Should we consider charging late payment penalties quarterly?

As above, the late payment should trigger the penalty; the penalties shouldn’t be “banked”… and anyway, they should be merged with the return penalties.

Q15. Should we consider allocating employers to a quarterly stagger period for both late payment and late filing penalties under RTI?

No

Q16. Are there any particular easements that we should consider for new employers?

You need first to provide information, training and support. Until those are in place – and I don’t believe they are at present, and I don’t believe HMRC has the resource to provide them on a continuing basis – then no penalties should be chargeable.

Q17. Do you have any views on applying interest to late payment and late filing penalties under RTI?

I think penalties should be clear, simple and immediate. And collected. There should be no need to apply interest if you apply active collection methods.

Q18. Do you have any views on applying a late payment penalty as well as interest where further sums become due for a period?

I don’t think it’s a good idea. There should always be the possibility of drawing a line under the past and moving on. So if someone fails to make an RTI return and payment it should be clear to them they’ll be charged a proportionate penalty and it should be collected immediately – and if possible (depending on the “payment period”) before the next return and payment are due.

Regards

Posted in Employment, HMRC, RTI, TIINs | Tagged , | 1 Comment »

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Have I got news for you? (Well, have I?)

July 23, 2012

There’s been some very poor reporting of the speech David Gauke made this morning at the Policy Exchange – “cowboy” tax advisers will be forced to “name and shame” their clients, for example.  No they won’t, and, don’t be daft.  Some journalists need to do some research that doesn’t involve google once in a while.

The speech itself is interesting, though, in part because the Minister has a go at what’s acceptable and what isn’t in terms of tax planning:

Legitimate use of reliefs is not tax avoidance:

Claiming capital reliefs on investment is not tax avoidance – when those reliefs were introduced precisely to encourage the investment in question.

Claiming reliefs against double taxation is not tax avoidance – when the alternative would be taxpayers paying tax twice on the same income.

Claiming back tax on legitimate charitable donations is not tax avoidance – any more than ticking the ‘gift aid’ box is.

Not paying tax on your pension contributions is not tax avoidance.

Taking out a tax free ISA is not tax avoidance.

Quite.  (Although you then ask yourself why we then had the ill-conceived consultation on capping charitable tax reliefs…???)  

Buying a house for personal use through a corporate entity to avoid SDLT is avoidance.

Channelling money backwards and forwards through complex networks for no commercial reason but to minimise tax is avoidance.

Paying loans in lieu of salaries through shell companies is avoidance.

And using artificial ‘losses’ deliberately accrued to claim back tax is avoidance.

To which we say “yes!!!!” (And, when are you going to give HMRC the resources to do something about it??)

Where, though, do we find the announcement that leads to the “name and shame” the “cowboys” headlines?  Well, a consultation IS announced:

Today we consult on ways to improve the information available to the public on avoidance.  Publishing warnings for all to see, and making it easier for taxpayers to see if their adviser has promoted failed avoidance schemes in the past.

(which, you will note, suggests that it’s information about advisers that might be made public, not about their clients)

Let us turn, then, to the Tax Updates and Consultation Tracker helpfully provided by HM Treasury, which lists as To Be Published in July a consultation on “Disclosure of tax avoidance schemes (DOTAS)” Hmmm…. the accompanying PDF helpfully elucidates that this will be

Consultation on extending the DOTAS hallmarks so as to capture avoidance schemes that do not currently have to be notified.

Because, as anyone who works in tax would already know, there is already a regime which says that, if you’re going to market an avoidance scheme, you have to tell HMRC about it.  You have to give it a reference number, and you have to tell the people who buy the scheme from you what the reference number is, and they have to include the reference number on their returns.  Avoidance, not evasion, remember?  These are people who are trying to outsmart the taxman, not hide from him.

So have I got news for you?  Or, to put it another way, is this consultation “news” at all?

Well we don’t know what it’s going to say yet, do we.*

But…

Well…

Look at the briefing note which the Law Society produces for its members, telling them what their responsibilities are if they are the promoters of a scheme and reassuring them that they aren’t going to be asked to violate their professional ethics by disclosing privileged information and they aren’t going to be caught by the legislation if they simply give advice to their clients on a scheme that someone else is promoting.

And turn to section 9, “more information”, and the list of legislation on disclosure of tax schemes.  There are thirty two of them.  So far. Including

I seem to recall that David Gauke said, in the foreword to Tax Policy Making: A New Approach that

Business and tax professionals have previously criticised the tax policy making process as piecemeal and reactive, pointing to the wide range of policy announcements in recent years that have been unexpected and insufficiently thought through.

We could discuss whether this vast train of DOTAS legislation is the result of “piecemeal” policy development that hasn’t been sufficiently “thought through”, or is a sensible use of an iterative approach.  Or we could just say that it’s the tax authorities and the tax avoiders playing whack-a-mole.

As the Minister himself said in his speech today:

There are some who might say that consultation documents on tax administration are often an effective cure for insomnia, but this is one consultation that will keep the promoters of aggressive tax avoidance schemes awake at night.

Um… are you sure, Minister?

 

[*Update: not twenty minutes after I’d posted this, I saw in my twitter feed a tweet from Tax Journal which had a link to the consultation itself.  So we DO know what it says.  But – having read through it – I’m afraid the rest of this still stands.  Sorry and all that.  Oh, and could someone from the Treasury please explain why they bother having a tax consultations tracker at all if it isn’t up to date, please?  Thanks!]

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Manufactured payments

June 21, 2012

I can’t pretend that I understand the legislation on Manufactured Payments.  In fact, I can’t actually pretend I have even *read* the legislation!  I barely managed to stay awake while I was reading the consultation document.

What I DO know something about, is what the government has promised to do when it contemplates making a change to legislation that will have an impact on business, and in this case it seems to me that it hasn’t done it.

First of all let’s look at what’s being proposed.  You don’t really need to know what a manufactured payment is for these purposes; let’s suppose you replace the words “manufactured payment” with the words “complicated thing”.

 1.5 In making these proposals it is the Government’s aim that as far as possible the changes to these tax rules should:

  • reduce the compliance burden on both payers and recipients of manufactured payments;
  • neither impede normal market transactions nor act as an incentive to transactions;
  • provide consistency of treatment between manufactured payments and similar payments made under derivative contracts such as swaps;
  • be consistent with the trend in recent years for taxation of financial instruments to follow the accounting treatment and for payments between UK companies to be paid without deduction of tax;
  • reduce the potential for tax avoidance.

What I take from this is that the government proposes to make the tax treatment of manufactured payments simpler, close down a tax avoidance loophole involving double taxation relief, reduce the potential for new loopholes to be thought up, and make life simpler for everyone.

As a TIIN specialist, I therefore turn next to the TIIN to see what that does to the numbers.

Page 22 of the document shows there will be no impact on tax receipts until the 2014/15 tax year, and that the effect after that is expected to be “negligible”.  I comment in passing that the TIA should begin when the legislation is due to be presented, not 2011/12 which is neither here nor there at this point when we are already in the 12/13 tax year!

The main question to be addressed in a TIIN is – why are you doing this?  Given that there is no exchequer impact from the change, then I would have expected the reason for change to be a saving in the administrative burden on companies involved.  However there is no attempt to quantify this: let’s look at the impact on businesses and civil society organisations:

Most businesses will not be affected. Those businesses involved in stock lending may benefit as the abolition of the need to deduct tax from some payments should lead to reduced administrative burdens. The prices of stock lending and repo transactions may need to be adjusted to reflect changes in the tax credits due to different participants in the market. There are likely to be transitional costs involved in changing IT systems and adjusting pricing models.

There’s no saving to HMRC either: “The impact on HMRC will be negligible as only a small number of staff are involved with manufactured payments.”

And there’s nothing else: “No other impacts are envisaged”

So why are we doing it?

Chapter 3 of the condoc, the “case for change” says:

3.6 More generally, there has been a trend in recent years towards the abolition of any requirement to deduct tax where payment is made by one UK company to another.

3.7 In addition the current rules are extremely complex and now run to over 100 pages of legislation. This complexity to some extent reflects the need which has arisen in the past for frequent changes to the legislation to defeat avoidance schemes.

3.8 HMRC continues to receive disclosures of avoidance schemes indicating that this area remains vulnerable to avoidance risk. Simplifying the legislation, and removing the need to deduct tax, will reduce this avoidance risk.

I’m interested in this idea that there’s a “trend” – sounds nice and organic, doesn’t it, as if we’re simply going with the flow.  But tax isn’t a force of nature, it’s a wholly manufactured (to coin a phrase) object, and we as citizens own its existence and – in the persons of our elected government – determine its design.  So a “trend” isn’t a reason to change.

Doing away with complexity is the only plausible reason given for change, and you might think that doing away with 100 pages of tax legislation was a desirable objective in itself.

But if that’s the case, then how much will it cost to do it?  What is the cost/benefit analysis of the change?

There must be some clue of what’s at stake if we don’t do anything at all, surely?  And there must be some idea of how much it costs to bring a piece of legislation before Parliament?  Maybe we should compare one with the other and see if the game is worth the candle?

Here’s the formal response I sent:

This is an individual’s response and is also posted online (with commentary) on my blog at https://tiintax.com/.
1.  The TIA begins its consideration with 2011-12 which is of course already in the past.  Surely the five year period under consideration should begin when the legislation is expected to be introduced, ie 2013-14 or at the earliest the current tax year, 2012-13?
2. There is no reasonable cost/benefit analysis in the TIA or elsewhere in the consultation document.  It is asserted that abolition of 100 pages of legislation will ease the administrative burden on affected businesses but the number of businesses affected is not given, nor is the administrative burden (measured by the standard cost model) calculated.  There are several forms and records listed for abolition and my understanding is that they should easily be capable of look up in the SCM and I am curious why this has not been done.
3.  Nor is there any reasonable consideration of the comparative costs of undertaking this change (the costs of the consultation itself and of the Parliamentary and other time required to pass the necessary legislation) as against the costs (the risks of tax avoidance) which would apply if there were no change.
4.  I can only therefore conclude that either this consultation document is seriously defective in its failure to present the cost/benefit analysis of making the change, or else the case for change is not made and the proposals should therefore be dropped.
5.  Sorry to give you what may seem an unhelpful reply but I would also be grateful if the consultation coordinator would look at this as a complaint at the failure to conduct a consultation in accordance with the government’s Code of Practice on consultations.  This says that “Estimates of the costs and benefits of the policy options under consideration should normally form an integral part of consultation exercises, setting out the Government’s current understanding of these costs and benefits.” and the Tax Consultation Framework additionally promises that, at each stage of the consultation, government will set out “its current assessment of the impacts of the proposed change and seek to engage with interested parties on this analysis.”  I cannot see that this has been done in this case.

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