Regulation - a suggested protocol

We seem to have reached a consensus that an independent regulator would be a less bad option than being regulated by HMRC. We have two good suggestions about how this might work, reproduced here :

From CD :

  1. ALL existing agents should be registered without question.
  2. There should be NO fees involved.
  3. If HMRC feel that an agent isnt up to standard (whether qualified or QBE) they should put their case together with evidence in support to an independent body.
  4. The "accused" should them have full access to the file, and the right to require any further reasonable information he/she requires - then prepare a "defence".
  5. Whether HMRCs claims are upheld or not should themn be for the independent tribunal to decide either on the papers submitted, or, at the "defendants" discretion, at an oral hearing.
  6. The tribunal then has the power to remove the accused from the agent list, or order additional training, or indeed find the case unproven and award damages against HMRC for distress caused.
  7. This should be totally independant of HMRC and the institutes - but - should be binding on both.
  8. When a case is refered to the tribunal, until such time as the agent is removed from the list (if indeed they are) HMRC must either continue to accept accounts submitted without prejudice, or, pay a weeky set fee of, say, £500 a week to the agent for loss of earnings until such time as the case is heard.

This would ensure that innocent agents dont suffer unduly, and, should ensure that HMRC dont put frivolous cases before the tribunal.

Separately, but not necessarily opposed to CD, OGA has offered :

The point is ... you got that bit of paper for a reason 30 - 40 years ago and that got you in a club. It is up to the club to ensure the members stay up to scratch or turf them out if they don't, not HMRC.

If HMRC decide on an agents list and accept the ACCA or ICA qualification ("the club" to keep it simple) makes you fit to be a tax agent, then all members of those clubs with the relevant certificates should be able to be agents. If HMRC has a problem with a particular agent HMRC should deal with the club not the members individually, and impose sanctions of the club if it doesn't keep its house in order. If the club investigate the member and decide they are competent, then tough on HMRC, they should not be able to dictate to the club who its members are.

What they do with those not in the club is a different matter, but it should be an independant body.

How about an afiliate scheme - the clubs had an ounce of enterprise they would set up such a scheme whereby for a fee they could assess a QBE agents files and grant them affiliate status, with may be a periodic check on files and a CPD and PII requirement - may be call them registered tax agents or similar.

Please would members now comment on the merits of regulation per se and the proposals above.

Comments
BKD's picture

My tuppence worth

BKD | | Permalink

I find little to disagree with in CD's proposal - seems to be a perfectly reasonable order in which to deal with the issues. I have a couple of minor reservations, though:

If unproven, HMRC should certainly be required to pay the agent's costs. But damages for distress? I'm not so sure. I guess it's relatively easy to demonstrate/fabricate distress in order to win some form of compensation, but it sounds very much like the American way of doing things - I abhor the ambulance-chasing "claim everything you possibly can" mentality (that is a comment aimed at such general behaviour and not at any one individual).

Loss of earnings? I'm not quite sure how that will arise. Temporary suspension from the register until the case is heard (I would argue strongly that there should in fact be no such removal) should not result in loss of earnings. It may make the agent's life a little more difficult in not being able to access certain information, but it shouldn't result in any loss of client income. Again, any additional costs incurred as a result of such suspension ought to be covered in an award of costs in the case of a successful defence (or is that defense?).

As for OGA's suggestion of an 'affiliate' scheme for QBE's - sorry, but I just don't see that working, however reasonable it may seem on paper. I can't see the likes of CIOT wanting to spend time and money - recoverable in terms of fees or not - in monitoring non-members. And I suspect that many CIOT members - who worked long and hard for their membership - would object to non-qualifieds piggy-backing on to the Institute in order to gain access to the register. Short-sighted protectionism? Perhaps, but that's the world that we live in.

RebeccaBenneyworth's picture

Opening comments from other threads

RebeccaBenneyworth | | Permalink

My own is to pose a question : will the board (in CD's suggestion) be drawn from the rep bodies? All of them? Anyone else in addition to a rep from each body?

weaversmiths comments on CD's proposal :

I agree with C_D's proposals. They appear balanced and well thought out.

BKD has commented on on CD's proposal as follows :

 I find little to disagree with in CD's proposal - seems to be a perfectly reasonable order in which to deal with the issues. I have a couple of minor reservations, though:

If unproven, HMRC should certainly be required to pay the agent's costs. But damages for distress? I'm not so sure. I guess it's relatively easy to demonstrate/fabricate distress in order to win some form of compensation, but it sounds very much like the American way of doing things - I abhor the ambulance-chasing "claim everything you possibly can" mentality (that is a comment aimed at such general behaviour and not at any one individual).

Loss of earnings? I'm not quite sure how that will arise. Temporary suspension from the register until the case is heard (I would argue strongly that there should in fact be no such removal) should not result in loss of earnings. It may make the agent's life a little more difficult in not being able to access certain information, but it shouldn't result in any loss of client income. Again, any additional costs incurred as a result of such suspension ought to be covered in an award of costs in the case of a successful defence (or is that defense?).

And from chatman : I agree with Old Greying Accountant. Nicely put.
 

Over to you.

RebeccaBenneyworth's picture

thanks BKD

RebeccaBenneyworth | | Permalink

I'm on a slow internet connection, thanks for reposting. I made some other pertient comments on another thread - although before CD set it out well. I think, however, it might add to this debate here.

As far as I am aware all of the professional bodies have an oversight system - I had the pleasure of a visit in early February (having declined 31 January). But as I have said, the information, the data about the agent's performance MUST come from HMRC as they have this data. So any oversight board would have to accept HMRC's input by way of a "complaint" about an agent's performance. Is a single board drawn from the various bodies acceptable, and would non affiliated agents also pay something for the "Tax Agent Oversight Board".

 

Old Greying Accountant's picture

Both I think

Old Greying Acc... | | Permalink

The "list" should be for QBE's, members of a "recognised" body are under their juristiction and should be dealt with separately. I am not being elitist, but surely that is the whole point of them being "recognised" bodies!

But, why not simplify? Why not just have the list of debarred agents, derived using CD's guidelines, and HMRC can only refuse to deal with agents on that list?

cymraeg_draig's picture

To address the issue of compensation/Loss of earnings

cymraeg_draig | | Permalink

Loss of earnings? I'm not quite sure how that will arise. Temporary suspension from the register until the case is heard (I would argue strongly that there should in fact be no such removal) should not result in loss of earnings.  Posted by BKD on Tue, 07/06/2011 - 10:05

 

Let's consider a few facts -

  1. An agent facing the tribunal could be fighting for his business, his future, his livlihood - lose that and he could lose his home etc - those are the potential consequences ............ so there is no such thing as an unimportant hearing.
  2. HMRC can (and will) take as long as they need and burn up resources without regard to cost, manpower etc - they dont pick up the bill - the taxpayer does.
  3. By comparison the agent probably works alone and has limited resources.  
  4. Now - assuming HMRC are claiming that accounts or returns are routinely erroneous obviously the first thing the agent will do is review - reanalyse - indeed redo those accounts. His first line of defence is, of course, to prove they are right. 
  5. Any technical points are going to require the relevent legislation locating, and any precedents tracked down, to substantiate the agents actions.
  6. Assuming HMRC dont file complaints on the basis of one error, there could I assume be numerous files to review in detail.
  7. There may well be statements needed from clients.
  8. Quite frankly I can see how an unrepresented agent could spend 2 months solid preparing his defence.
  9. Temporary suspension is not going to be that "temporary".
  10. Firstly it would be illegal (Article 6 HRA) to rush through a hearing before the accused has had sufficient time to prepare his defence - so I cannot see how any hearing can take place in less that 6 months. 
  11. Article 6 HRA refers to "criminal proceedings" - BUT, befotre someone says these are not criminal proceedings, the courts have ruled that where someones freedom is challenged including their freedom to earn a living, the potential consequences are so great that the same rights should apply.
  12. Legal representation - Given the serious consequences every accused should be entitled to representation and to be able to call experts to testify on his behalf.  Those who can't pay for this should have it paid for them (like legal aid).
  13. Lastly, the stress of being accused can have devastating effects on the accused. Even if the agent wins his case, will he ever be able to trust HMRC again? What effects will the stress have upon him ?  I have seen cases of defendants totally exonerated who, due to the stress they were under, have suffered terrible after effects and, in some cases, committed suicide, as a result of the months of stress.

So - yes there should be damages for stress, and for loss of earnings. I could see how someone needing professional representation, calling an expert witness, and spending 6 months preparing and constantly reviewing a defence (which is what defendants natuarally do)  whilst awaiting a hearing, could run up costs of £100k +.

If a mechanism is not put in place, then I can forsee cleared agents puruing claims through the civil courts, and I can confidently predict that the courts will be less than amused if they have to adjudicate on such matters when the tribunal should have a process built in for the speedy resolution of cost & damages awards.

 

 

cymraeg_draig's picture

.

cymraeg_draig | | Permalink

The "list" should be for QBE's, members of a "recognised" body are under their juristiction and should be dealt with separately. I am not being elitist, but surely that is the whole point of them being "recognised" bodies!

 

Posted by Old Greying Acc... on Tue, 07/06/2011 - 10:49

 

Sorry but I totally disagree.  There must be a "level playing field". Your suggestion implies that those of us who belong to "the right club" should get preferential treatment.  Face it, the professional bodies are not going to admit that "their" members are incompetent. Justice should be the same for all - otherwise it bis not justice at all.

 

cymraeg_draig's picture

As an aside - FEES

cymraeg_draig | | Permalink

Assuming (and I know HMRC say it wont cost) that there is some sort of "membership fee" attached to being "registered", this too needs careful consideration. 

Surely it cannot be right that a large firm with, say 5,000 clients, pays the same fee as someone retired with half a dozen clients they look after to earn a bit of pin money, or the mother working part time from home whilst the kids are at school. 

So - I would suggest a simple "levy" of, say, £10 per client. HMRC have a record of how many clients each agent has registered so its hardly rocket science to calculate.  And the agents (if they wish) can simply stick £10 on each invoice to recover the cost from their clients.

 

My thoughts

pauljohnston | | Permalink

1 C_d Has made a very good point about Govt bodies and the time that it could take to bring details to oversightboard.  However I would like to see a half-way stage.  That is when HMRC have concerns and we have in place help for those agents that are not up to scratch excluding the rogues. No suspension or knowledge to others except the absolute minimum and help is given to bring the under-performer up to speed.

2 C-d comment re all being regulated by one regulator (I suggested Institute of Tax ProfessionalS) is a must otherwise a level playing field will not seen to be available. I dont want the whole idea to go down because of the Q/ug arguement.  To be honest no one has a qualification - being a good agent.

3 £10 a client could be a bit steep, unless HMRC allow all clients of super agents a £10 tax credit against any tax bill.  It may be steep to those who do tax returns in the £80-£150 range

 

 

Fees

wblewis | | Permalink

While I agree with most of CD's proposal his suggestion of fees/levy strike me as an indirect or stealth tax. This whole consultation should be aimed at protecting the taxpayer not increasing the cost of a simple tax return.

johnjenkins's picture

mmmmm

johnjenkins | | Permalink

Not too sure about stopping an agent from trading. Correct me if I'm wrong but all we are talking about is a "fastrack" agents list. If an agent is thrown off that list presumably they would still have access to other info as before or even via client. I suppose a "list" of minor and major offences drawn up and agreed by agents and HMRC might get rid of the need for expensive hearings. Is HMRC ready for major interaction with agents????

 

BKD's picture

Compensation

BKD | | Permalink

I don't think there's any need to address all the points you make - there is little that I disagree with (though I'm not certain that an individual would be "fighting for his livelihood" - not directly, anyway - in front of a Tribunal. This is not about getting an agent struck off or being put out of business - it is about his place on the register of enrolled agents. Yes, I accept that removal from the register may make his job harder, and perhaps ultimately result in loss of clients. Remember, as things stand, the proposal is that enrolment will not be mandatory - so if certain agents are able to continue in business without enrolling, it follows that removal from the register does not automatically mean that the agent goes out of business).

But to the main point:

"So - yes there should be damages for stress, and for loss of earnings. I could see how someone needing professional representation, calling an expert witness, and spending 6 months preparing and constantly reviewing a defence (which is what defendants natuarally do)  whilst awaiting a hearing, could run up costs of £100k +."

Perhaps I simply misunderstood you when you referred to loss of earnings - to me that normally means loss of income. What you seem to be describing are additional costs. Yes, it is possible that an agent's earnings could be diminished if he has to divert his chargeable time elsewhere in preparing for the hearing - but I would suggest that should still be brought within an overall claim for compensation. But we're splitting hairs - I think we're pretty much agreed on the principle of recompense for direct financial loss, howsoever caused.

cymraeg_draig's picture

Dont underestimate how seriopus this is -

cymraeg_draig | | Permalink

I think we're pretty much agreed on the principle of recompense for direct financial loss, howsoever caused.

 

Posted by BKD on Tue, 07/06/2011 - 11:46

 

As I thought I had made clear - it's not just direct costs.

There is a lack of understanding by the public about the psychological damage caused by being wrongly accused. I'm not just talking about murder accusations, I have seen people wrongly accused of the most trivial things who have been damaged for life (no thats not an exageration). 

Effectively under the proposed scheme any agent "accused" by HMRC is being accused of being either incompetent or bent. Both, I would suggest, are very serious accusations and will adversly affect the accused. 

Similarly, instead of "banning" if we are only talking about "approved" and "non approved" agents, the FACT is that HMRC will target "non approved" agents, so again the consequences of being "demoted" would be virtually the same thing as being banned from trading. 

   

Old Greying Accountant's picture

yeah but no...

Old Greying Acc... | | Permalink

The "list" should be for QBE's, members of a "recognised" body are under their juristiction and should be dealt with separately. I am not being elitist, but surely that is the whole point of them being "recognised" bodies!

 

Posted by Old Greying Acc... on Tue, 07/06/2011 - 10:49

 

Sorry but I totally disagree.  There must be a "level playing field". Your suggestion implies that those of us who belong to "the right club" should get preferential treatment.  Face it, the professional bodies are not going to admit that "their" members are incompetent. Justice should be the same for all - otherwise it bis not justice at all.

 

 

Posted by cymraeg_draig on Tue, 07/06/2011 - 10:57

But, if you read down, my real feeling is the list should be of excluded agents not included ones, with your stages to be gone through before being debarred - case in point, to work with children the list is of those who can't, not those who can - but, then again, cynically, with the effectiveness of CRB checks,  may be that proves your point that this is just a revenue creating ruse!

But what is the point of a recognised body if it is not recognised?

BKD's picture

Effectively under the proposed scheme any agent "accused" by HMR

BKD | | Permalink

That is one view. Some of us are less cynical.

I think it is important to understand that it is not a case of the agent being 'put on trial' the moment he is perceived as stepping out of line. Only where the 'agent view' of the practice as a whole is significantly (whatever that may mean) at odds with similar-sized etc practices do HMRC intend to intervene. And at that stage, all that is being suggested is that HMRC will offer support or technical assistance. I would suggest that we go for a '3-strike' procedure - if the agent fails to implement steps suggested by HMRC, and matters do not improve, the agent should be put on warning that he may face the prospect of disenrolment. Again, important to understand that this should apply only to significant deviation (I accept that 'significant' needs defining) from the norm.

One of the principal features of the proposals is to give agents enhanced access to HMRC database records (some will argue that we should already have such access, but we don't - so it's a pointless claim). I see no reason why HMRC should not be allowed to take action against those agents that appear to be unable to use that information properly. But to stress - the action should be proportionate, with the agent given every opportunity to rectify matters before the ultimate sanction of disenrolment.

RebeccaBenneyworth's picture

Adding relevant comments from other threads

RebeccaBenneyworth | | Permalink

Just drawing in the comments on this from other threads, so that we have all of the relavant content in one place.

All of these comments relate to CD's propsal.

accountright (Polly) said : Well said that man! Yes, I'm with C_D

pawncob commented :A jury of our peers
Whilst supporting WD's proposals, I am concerned as to the make up of the tribunal. If I found myself in front of them, I'd want them to understand the reality of dealing with HMRC (and clients!), so I'd want a jury of my peers rather than a selection from academia/governing bodies etc.

johnjenkins said : I'm with WD. However this will only get rid of the incompetants off the agents list. No doubt they will still be able to get info, but not on a fastrack basis.

So my point is and has been all along, from HMRC's point of view is it all worth it. What is the best they can hope to achieve if WD's plan is adopted?

And CD further added : I agree that the "board" should be made up of QBE's as well as members of the various institutes. ALL should be actively engaged in day to day practice.

Quite how an impartial tribunal can be found I'm not sure. What we DON'T want is something like the old General Commissioners which were rather akin to magistrates - and had little understanding of life in the real world.

 

RebeccaBenneyworth's picture

I do think

RebeccaBenneyworth | | Permalink

that we need to think about costs and the proportionate response when an agent "needs some help" - i.e. standards are way below that expected. HMRC "disengaging with" an agent has only happened once in recent past as far as I know - CL case - so a really robust system of oversight is needed for that. But if there is no suggestion that the agent is on this path, is there a cheaper and simpler way? Even lower level than reporting to professional body (if a member), so we have three stages : (I've added a fourth which is to come later)

  1. Contact with a view to support and assistance. Informal, but a record provided to agent so that what has been agreed is documented. Nobody else knows about it - no embarrassment etc.
  2. Still no joy - report to professional body is a member. If not, what??
  3. Serious allegation of incompetence but not dishonesty. Must be endemic incompetence of the severest form. Goes to the new "Oversight board" to make recommendations. HMRC may apply to disengage. Porcess follows CD's protocol?
  4. Allegation of dishonesty - not being consulted upon yet - this will come out later this year, but if we have a professional oversight board then they could handle this too, unless HMRC wish to proceed with a criminal investigation. If criminal then I guess that's where the profession signs off and the lawyers sign in.
BKD's picture

Quite how an impartial tribunal can be found I'm not sure

BKD | | Permalink

Virtually impossible, I would suggest. Even if you were to take half a dozen people off the street, their view of HMRC is likely to be such that the agent is immediately in a favoured position.

Personally, I believe that a panel from the various professional bodies is as close as we are likely to get. They all have their own codes of ethics, CPD requirements etc, so they know how a competent agent ought to be running his practice. And, whilst they may have their members' interests in mind, they also have a responsibility to the respective qualification not to allow the standard of that qualification to be diminished by irresponsible or incompetent behaviour of their members. We are not, after all, talking about union leaders here.

I have every confidence that such a panel would be as even-handed as it could possibly be. I don't believe that a panel made up of currently practising agents could be anything like impartial (particularly if it comprised certain Accounting Web contributors - sorry, couldn't resist).

johnjenkins's picture

Got

johnjenkins | | Permalink

to disagree with you there BKD.

I think that the panel, board, why. should be made up of agents and staff from HMRC.

Normally on AW we speak as we find with no bias. If we find HMRC misbehaving we say so and we also do not tolerate any body that wants to bring the Accountancy profession into disrepute.

The only reason HMRC are getting a real slagging at the moment is because their change of "modus operandi" is causing no end of problems which they don't appear to be able to sort out.

The answer, to me, is more interaction between HMRC and Agents, with a view to getting the job done.

To me Institutes and bodies are there to make sure everything runs smoothly, and sort out problems.

I do accounts for clubs, charities etc. and all too often it's unworkable rules that cause most of the problems.

So we need rules made by the people who have to live with them on a daily basis to make the system work.

Sermon over!

BKD's picture

John

BKD | | Permalink

As I said (and CD indicated) it is unlikely that we will ever get to the ideal panel. A panel comprising agents and HMRC representatives may, overall, be neutral but I can't help thinking of the arguments and stalemates that would arise - who would have the casting vote? I don't think it's a case of agreeing to disagree, but useful discussion - perhaps the subject of the next poll, Rebecca?

(But as for AW members speaking without bias - hmmmmm  ;) )

pawncob's picture

Right up the nose

pawncob | | Permalink

Like WD I've got up HMRC's nose on more than one occasion, and I would hate to think that my activities upset them so much that they feel the need to give me a "first strike". But it does worry me that this could be another sword which they hold above my head. It sounds like the police issuing warnings and cautions which have very little legal force, but still remain on your record for a long time.Do we envisage an expiry date on "strikes"?

cymraeg_draig's picture

Jury

cymraeg_draig | | Permalink

A panel comprising agents and HMRC representatives may, overall, be neutral but I can't help thinking of the arguments and stalemates that would arise - who would have the casting vote?  Posted by BKD on Tue, 07/06/2011 - 14:36

 

There shouldn't be a "casting vote" - like a jury it should be unanimous, or automatic "acquital".

 

Why do you think

pauljohnston | | Permalink

that because you have caused problems to HMRc it is going to single you out, unless there is reason to do so because of the items already mentioned here and in related posts relating to competence?

BKD's picture

it should be unanimous, or automatic "acquital"

BKD | | Permalink

In an ideal world, perhaps (but even so, not all juries are required to reach a unanimous decision). But let's get real. If, as some have suggested, the panel ought to comprise practising agents and HMRC representatives, practically every case would result in acquittal - since I can see very few unanimous decisions being reached with that make-up (again especially so if certain AW contributors were to sit on the panel ;)  )

pawncob's picture

They're not robots

pawncob | | Permalink

@pauljohnston
As BKD says, HMRC isn't an "it", the organisation comprises individuals, who (may) bear grudges or wish to exercise control over others. Read Rebecca's story about HMRC threats, intimidation and assault.

cymraeg_draig's picture

Singling out -

cymraeg_draig | | Permalink

Why do you think

that because you have caused problems to HMRc it is going to single you out, unless there is reason to do so because of the items already mentioned here and in related posts relating to competence?

 

Posted by pauljohnston on Tue, 07/06/2011 - 15:34

 

OK - let's use the case I am currently dealing with as an example. I cant give too much detail as its sub judice but -

  1. Agent files complaint regarding behavious of tax inspector.
  2. Tax Inspector gets slap on the wrist (and promotion prospects damaged)
  3. Suddenly EVERY return submitted by the agent during the last 12 months is pulled for enquiries under s9A.
  4. ALL these "enquiries" are commenced on the same day by the Inspector complained about or his/her collegues.
  5. Several clients report receiving phone calls from the Inspector making slanderous allegations about the agent. One states the Inspector told them to assault the agent.
  6. Cost to the agent - destroyed business, turnover lost over the next 15 years in excess of £1million. 
  7. Immediate cost to agent - destruction of business equals loss of his home, and family.  
  8. Incidently, the agent is perfectly competent and no evidence whatsoever to the contrary has even been offered.

Now, I have the file on my desk regarding this case, it's clear cut and blatant.  Anyone care to argue that HMRC cant single out and unlawfully harass an agent ?

 

johnjenkins's picture

@pawncob But

johnjenkins | | Permalink

isn't that what we are trying to overcome???????

Isn't it high time the "them and us" became a thing of the past.

HMRC are on the back foot and they know it so they are going to have to compromise and get rid of the GB indoctrination sooner or later.

So Rebecca it's up to you to show HMRC that if they really want a proper and sustained dialogue between agents and themselves they need to grasp this opportunity by the unmentionables and move forward.

So endeth the 3rd lesson!

BKD's picture

"Anyone care to argue that HMRC cant single out and unlawfully h

BKD | | Permalink

It depends - on whether you are referring to an individual or to HMRC as a body.

Of course, as in all walks of life, there can be thoroughly obnoxious and vindictive individuals - I could also cite the example of the Inspector that was 'transferred' after physically assaulting an agent during an enquiry meeting.

Yes, ultimately any corporate body or organisation needs to be held accountable for the actions of its individual staff - but I still disagree with the notion that HMRC - as an entity - singles out individuals for unfair treatment. Spiteful officers, perhaps - the organisation, no.

johnjenkins's picture

@WD

johnjenkins | | Permalink

Do you think that differences can be put aside and a real raport, with the aim of a future better relationship, with HMRC is possible??????

RebeccaBenneyworth's picture

John

RebeccaBenneyworth | | Permalink

We are sooo on the same page. Great comments above. thanks v much for your contributions.

And for anyone else reading this thread - I do think this is the most constructive thread to come out of our debates, and I'm really looking forward to some of the other detail we need to discuss later such as security issues. I really do feel that if we stick with it we can make a really important contribution to the debate.

cymraeg_draig's picture

NO

cymraeg_draig | | Permalink

Do you think that differences can be put aside and a real raport, with the aim of a future better relationship, with HMRC is possible??????

 

Posted by johnjenkins on Tue, 07/06/2011 - 17:03

 

In a word - NO. 

I think so much damage has been done by HMRC that no one trusts them. Try filing a complaint, I absolutely guarantee that the initial response will be a blatant whitewash.  Talk to them, they promise to call back, but very rarely do.  They make promises to the public about improving standards, then we discover they lied (not just to us or the public but to parliament too) for 2 years over the coding fiasco. 

Try getting them to make a repayment, it's like knitting fog, but it's a different matter altogether if tax is owed to them.  Now they have a "debt collection" firm harassing taxpayers on their behalf.  A quick google search shows that the reputation of the firm in question is appalling.

The Commons Select Committe found them "unfit for purpose".

This is why their ideas of regulation are so unacceptable, because without absolute safeguards and guarantees, no one can trust them.

 

 

The Unmentionables !!

Peter Tucker | | Permalink

"So Rebecca it's up to you to show HMRC that if they really want a proper and sustained dialogue between agents and themselves they need to grasp this opportunity by the unmentionables and move forward."

Excellent words, but I wonder what "d8057" has to say on the subject? Wait a moment,  who is "d8057" ?

Well this is the nome de plume of a senior manager within HMRC who regularly checks the posts on this website. He is senior enough to be the lead on the introduction of Real Time Information for PAYE, which originally intended to "change" not only the electronic transmission process but by default, the business process of everyone involved in operating PAYE Payroll.

Interestingly he does not appear to have made any postings himself, but then perhaps this says more about the attitude of HMRC senior management than it does about his views or thoughts on the way HMRC should progress in the future.

May be I should be accused of being old and cynical, but I suspect I am not alone. I still cling to the idea that we have a Civil Service (emphasis on Service) but this idea is often drowned with cries of "Customer", "Segmentation", "Behaviours" and "Regulation".

Dialogue takes place between Client and Agent, whatever that invented word is meant to mean. HMRC are supposed to calculate and collect Tax and ensure that systems are in place to audit the process. There is no dialogue with "d8057", we dont even know that his name is .......... 

@ Peter tucker

pauljohnston | | Permalink

I think it is great that D0857 (0857= d of b ?) is able to enter into Accounting Web.  It does show that HMRC take it seriously.  It must be very difficult to see matters from this side of the fence when one is on the other side.

I am not suggesting that all the critiscm is not due but I for one am glad that someone on the other side (of the fence) can see that there are great problems that need to be addressed.  Any progress is better than none.

BKD's picture

Balance

BKD | | Permalink

"no one trusts them."

The current results of the poll that you requested would suggest otherwise.

"Try filing a complaint, I absolutely guarantee that the initial response will be a blatant whitewash."

Not in my experience

"Talk to them, they promise to call back, but very rarely do."

Not in my experience 

"Try getting them to make a repayment, it's like knitting fog"

Not in my experience

 

All recent experience, and not one-off's

cymraeg_draig's picture

[removed by mod]

cymraeg_draig | | Permalink

[removed by mod - personal and unnecessary]

RebeccaBenneyworth's picture

Please please please

RebeccaBenneyworth | | Permalink

Don't start again. On this or any other threads. I really don't want to lose the valuable input that you both make to this discussion; both have offered well considered excellent contributions in between the squabbling and the debate would be poorer without you, but Becky will apply the moderation policy, and I would be sad to lose you both (or indeeed either of you).

cymraeg_draig's picture

.

cymraeg_draig | | Permalink

[removed by mod]

pawncob's picture

Agree with WD

pawncob | | Permalink

I think most of those who read it before its removal agree with WDs post.

cymraeg_draig's picture

I SEE

cymraeg_draig | | Permalink

[removed by mod - publically discussing moderation in a moderated thread is against the new rules]

 

 

 

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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