Planning our response | AccountingWEB

Planning our response

I shall be starting to pull together the evidence for our response next week, as I envisage it is quite a big job.

To gauge the view of as many as possible, I shall run a seies of polls so that I can get a big turn out on the key questions. I shall start them rolling next week, but if anyone has any suggested topics or questions for polls which are central to the consultation then please post a comment below and I'll get the polls set up.

The first and most obvious one to me (although it is the tail end of the consultation) is about how disenrolment should be handled. I'll dream up a multi option poll on that. I also have a bit in mind on enrolment, so I'll probably start that one rolling over the weekend.

Suggestions please.


disenrolement poll

jeep | | Permalink

Good morning Rebecca,

I think that the questions asked should include;

1. Should HMRC have the power to disenrole an agent?

2. Should a body independent of HMRC have the power to disenrole an agent?

3. Should an agent have a right of appeal against disenrolement?

4. Sholud the professional bodies have the right to disenrole an agent?

5 Should the professional bodies form a joint council to consider matters regarding the disenrolement of an agent?

6. Should a body independent of the professional bodies have the power to disenrole an agent?

7. Sholuld there be a process to allow agents to re-enrole following their disenrolement?

Framing questions that need a yes or no answer will make it much easier to collate the responses.

I hope that you find this useful and once again thank you for taking the time to collate a response to the condoc.

kind regards


Should disenrolment be 100%?

Ken Howard | | Permalink

Should disenrolment being an absolute ban on being an agent, or should there be levels of authority that can be revoked?

For example, if an agent is found to be wrongly making changes to PAYE codes, then surely the punishment should be taking away that ability, i.e. by a system of rights and permissions to withdraw services that have been abused.

Same with abuse, surely calling an HMRC officer a liar isn't as serious as a racial abuse or as a physical threat of violence, and as such there should be proportional punishments, that is, if found guilty - i.e. what if the HMRC officer really did lie - would calling them a liar be punished, even if it were true, because it was abusive?

I find it quite extraordinary that the proposal seems to be an all-or-nothing approach. I.e. either being allowed to be an agent with full rights, or being banned from being an agent at all. To me, an effective removal of your ability to operate your business is the most serious of sanctions and should have a full system of appeals/tribunals to safeguard abuse. It should be more along the lines of the ACCA/ICAEW disciplinary system where you can be struck off only for the worst kinds of malpractice, but otherwise are subjected to closer monitoring, or having restrictions placed on types of work you do, etc., rather than the ultimate sanction, and even then, you're still free to practice as non-qualified even if you're no longer ACCA/ACA.

I just see nothing but fear being introduced here, with accountants being frightened of challenging HMRC in fear of losing their livelihood.

Well done jeep and ken

pauljohnston | | Permalink

I have already posted that disenfranchment should relate only to the part of that agent's work that is not up to scratch.  Also I have suggested there should be a mechanism to allow him or her to show that the past problems are corrected. 


johnjenkins's picture


johnjenkins | | Permalink

should there be a need for dis-endoodrops?

If an agent is being dishonest (and that really is the only reason I can see for not being allowed into the sweetie bag - yes kids off school making grandad say and do silly things) then they should be prosecuted. To me there are no grey areas.

As I said when this condoc was first bandied - a great idea marred by compliance crap.

I would really like this to be a stepping stone for further HMRC - agent raport but I don't think it will ever get off the ground (hope I'm wrong).


ShirleyM's picture


ShirleyM | | Permalink

That's a very good point! Could HMRC refuse to engage with abusive taxpayers, or even criminals serving a sentence?

Can other government departments, eg. the law courts, refuse to 'engage' with solicitors, lawyers, etc?

johnjenkins's picture

Thinking about it

johnjenkins | | Permalink

a bit more deeply. Self-serve, by definition means we do not have to make contact with HMRC on a personal level as we will have access to all areas via computers. So following on if we think something should be altered and we don't have access, a simple e-mail to the department (which one????????) should avoid the need for any dialogue, which I presume is the object of the exercise from HMRC point of view.

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Group: HMRC Agent Strategy
A forum for members to share ideas, evidence and common responses to HMRC's consultation paper, “Establishing the future relationship between the Tax