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HMRC to deal only with 'good agents'

28th Oct 2015
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At the introductory event of the newly formatted Working Together, HMRC said that they were ‘acting on feedback’ from agents and as such would be trialling a series of interactive online sessions called "Talking Points”. The idea behind these sessions is to give agents the opportunity to talk with HMRC subject matter experts on different topics relevant to agents. The first “Talking Points” meeting was held on Friday 23 October.

If HMRC had been ‘acting on feedback’ then why were there not more attendees present?  But only 78 attended.

The subject matter was important– “what the Agents Strategy is seeking to achieve, how HMRC are seeking to implement it and where they are up to.”


To get the feel of the mix of attendees the session started with a couple of online poll questions. The first being on the question of qualifications – “which of the main four professional bodies were attendees members of - ICEAW, ACCA, AAT or CIOT or “others”’.  Interestingly 51% ticked ‘others’. The next question asked for confirmation of the number of clients - 68% had more than 100 clients.

The presentation itself

The presentation revealed HMRC’s concern about the level of competency of some agents. Their intention is to categorise each agent on a scale, the highest being “good/high risk”, the lowest being ”poor/high risk”.

If an agent is deemed by HMRC to be “good” then that agents’ clients will be given a “lighter touch” – what this “lighter touch” meant in practice was not detailed.

We were told that:

  • A “good/low risk” agent:

Adds Value: Due diligence, up-skilling the client, helping ensure compliance and aiding their growth and prosperity

Behaviour: Engaging with HMRC on a professional basis and in a professional manner

Competence: Meeting high professional standards and continued professional development

  • A ”poor/high risk” agent has:

Weak technical competence, lack of sufficient due diligence and lack of reasonable care:

Placing tax at risk and an unnecessary burden upon resource

Disengaged with HMRC processes: Unnecessary obstacles to good compliance

Abusive behaviours to HMRC staff: Disrupting and hindering enquiry work

Deliberate non-compliance: including dishonesty

The result will be that certain agents work will be deemed ‘unacceptable’ and as such that agent will be marked “Refuse to deal with (RTDW)”. The intention is to give ‘assured status’ to those agents they believe are “good” enabling this to be highlighted to potential clients.

A “good” agent will be given certain privileges. A list came up on screen of suggestions as to what those privileges should be. 70% of the attendees wanted a ‘Kitemark style’ recognition (obviously assuming that they themselves will be deemed “good”); 64% wanted quicker access to current HMRC helplines; 50% wanted easier access to subject matter experts and 33% wanted shorter enquiry windows.

Authors view – too many questions not answered

The content of this “Talking Points” session is very worrying. It is surely not HMRC’s remit to be judge and jury. What will be the criteria? Will the designation be only “good” or “poor” or with there be varying levels?  What about agents who specialise in sorting out problems? Will they be downgraded? What about the effect on the clients of a “poorly” rated agent – will they be subject to increased interest from HMRC?  What will be the procedure? Will there be any right of appeal? Will there be a ‘logo’ of some form that says that that agent is a “good” agent in HMRC’s eyes?

This sorting of agents into “good” or “poor” must surely be the sole responsibility of the professional bodies where an agent is a member.

When this idea was originally mooted a couple of years ago HMRC were looking to restrict full access to their site only to those agents who were large enough to be VAT registered. That idea has now gone but it is obvious that this is an area of regulation that HMRC are intent on imposing. As I say... worrying...and so far only 78 agents are aware.

Replies (7)

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Tony Margaritelli, ICPA Chairman
By Tony Margaritelli
28th Oct 2015 17:27

Good Agents

If you check out my blogs from July and May you will see that this is something that we at the ICPA amongst other organisations and Institutes have been trying to get HMRC to be open and and honest about. It goes under the banner of DAS Differentiated Agents Services whereby some agents will be treated differently than others. We are constantly raising this with HMRC and this webinar was virtually the first time they have spoken out. Tony Margaritelli Chairman ICPA 

Thanks (0)
Adrian Pearson
By Adrian Pearson
29th Oct 2015 08:40

Great if the reverse could apply

HMRC are both cheeky and hypocritical here.

How many hard working, frustrated accountants would love to label the whole HMRC machinery as "Refuse to deal with"?

Also, they want their cake and eat it - introducing "self" assessment for instance then expecting accountants to continue with their unpaid quality control service on behalf of HMRC.

In the words of Victor Meldrew, "unbelievable"!

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By Old Greying Accountant
29th Oct 2015 14:34

I would never ...

... now engage with HMRC on anything that is not directly client based, as there has been so much abuse by HMRC over the years that I am cynical to the point of believing the only reason HMRC allow such contact is to extract information to enable them to collect more tax and raise more penalties, and has nothing to do with making a working  and efficient (in terms of process not tax revenues!) tax system.

I think HMRC need to grade their own staff first though, before having the nerve to assess agents. We all know too that their "assessment" will be a tick box exercise with no intelligent thought behind it!

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By The Innkeeper
02nd Nov 2015 12:19

and how

will HMRC view the agent is rigorous in defending his (or hers) client's position? Will agents be considered 'good' if they always 'rollover' and agree with HMRC?

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Glenn Martin
By Glenn Martin
02nd Nov 2015 12:29

Refuse to deal with

Will they issue refuse to deal with notices to the large firms that sell schemes which allow the likes of Gary Barlow to avoid millions in tax or is that part of being a good agent.

This will be very difficult to roll out and i cannot see how it will work in practice.

How can they judge if you have "upskilled the client" merely from a tax return at the end of the year?

With regard to engagement with HMRC everything I do is online now as phone lines and posting documents just does not work. So if you file everything on line and on time are you classed

as a good agent even if the content is poor?

I imagine the reason agent become angry when talking to HMRC is they have probably been on hold for 40 minutes, when they get through you rarely get to speak to someone who actually can help or understands your issue.

If you did end up on the refuse to deal with list, do they write to all your clients and tell them that they need to get a new advisor?

I see this becoming a bit of a mess.


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By Old Greying Accountant
02nd Nov 2015 14:56

See my post here ....

... it's like getting the fox to guard the hen house!

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By vinylnobbynobbs
06th Nov 2015 09:56

"Woe fully Inadequate"

Having sat through this meeting I was surprised that HMRC now seem set to impose this on agents despite lukewarm assurances previously that this was not the case.

Having emasculated WT local meetings so that HMRC can now censor all output, you don't get to see the questions raised at these "meetings" and I suspect only a few are answered, carefully monitored.


So now an organisation, labelled woe fully inadequate, is to determine who it will, or will not (no doubt digitally) interact with.  Can we elect not to (digitally) interact with HMRC?

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