HMRC’s MTD equality assessment is late and lacking
The government’s equality assessment on Making Tax Digital is three years late with little evidence that anyone from disabled or minority groups was consulted. Wendy Bradley is unimpressed.
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"It’s late, it’s shabby and it doesn’t fill me with confidence"
I think that can be applied to HMRC in general.
Thank you Wendy for adding detail to what we already suspected.
HMRC simply do not care. Whether it is customer service, accuracy of data, their own reputation or even how they treat those who need particular help. This is a terrible indictment on their senior management some of whom should be considering their positions.
A web thought the above was so good it needed to be said twice. It isn’t and it doesn’t. Once is enough.
"What a missed opportunity. Remember the early days of ITSA when HMRC was confidently envisaging a future where there were computer terminals in post offices, libraries and enquiry centres so that everyone could access computers in places where someone was at hand to give them advice and help to get up and running online? Whatever happened to that? Times change. But you would hope they would change for the better."
I think the modern equivalent of this is that Software Developers and Accountants will provide assistance with using Tax and and Accounting software. The problem is that both will require hefty fees for support and advice on using this technology (no one is going to work for nothing) which will make it very difficult or impossible for some people to get the help they need.
I would hope that an assessment report would flag up this situation and HMRC would step up to the mark and provide unlimited help and advice for those (perhaps hundreds of thousands) people severely impacted by the unnecessary imposition of this MTD folly.
Equality does apply to IT ability and financial resources as well, something which HMRC seems to have misunderstood.
"I thought the point of impact assessment was to assess the impact while a policy was being developed " ... you and me both.
But it's actually worse than the mere lip-service that has been paid to the concept with regards to the missed opportunities for understanding potential (and unequal) impacts on taxpayers.
In the (now fairly distant) past I've sat on various informal groups that assisted in the 'impact assessment' of new policies *before* they were translated into legislation.
Then the assessment moved further downstream ... to gauging the impact after primary legislation but before HMRC produced specifications/guidance for software developers (including their own).
And now (as per MTD ITSA)?
The equivalent assessment has moved out into the long grass, along with the specification that has to be presumed lost in the jungle - despite the imminence of 'go live'.
There's absolutely no evidence that HMRC believe in the value of assessing anything, let alone in time to identify potential issues that could be corrected *before* they become problems.
And VAT is probably the area where MTD is most likely to be successful (VAT registered businesses have been used to filing quarterly returns for years and are familiar with how it works).
And yet I understand that some 200,000 businesses still have to sign up to MTD for VAT.
How on earth do they think that landlords with rental income of just over £10k are going to cope? Currently I think I could count the number of our landlord clients (and we have a lot) who keep their records electronically on one hand. Many of them are retired and a significant number do not use any technology. they really need to re-think this!!!! I am aware they may be able to apply for an exemption. Seems like we will be applying for a lot of exemptions.
And no, I can't/don't want to do their records for them quarterly.
Great article, Wendy, but it does just echo what we have been saying since MTD inception.
My view is that HMRC wanted to stand back and let the software developers Accountants and tax payers "get on with MTD".
Let me be clear, I think MTD is a great concept, without QU and on a voluntary basis, not mandatory.
Natural progression is always better and has better outcomes than forced coercion.
So guys when exactly our we going to "put our money on the table" and tell HMRC that we and our 12 million small and micro business clients are not playing their game any more. We tell them to make it voluntary and NOT mandatory. The current SA system works beautifully for me and my 60 clients. I'm more than happy to show HMRC that EVERY one of my clients has paid the tax owing to HM Treasury and their accounts are open for inspection. I want to know who they suspect are not doing it correctly and thus the tax gap will reduce with MTD ITSA - I want the EVIDENCE!!!!!. To then naively believe that putting it on a computer makes it all ok beggars belief. To err is human but if you really want to make a mess use a computer.
That would involve all our various Institutes taking a very different line with HMRC then the current cosy arrangements where they go out of their way not to ruffle any feathers.
Perhaps it's time to ballot the members and then refuse to implement it for clients if the majority decide and the Institutions back us up when things get tough.
But would the Institutions back us up?
I very much doubt it - they would be too scared to do it.
Perhaps we should instigate a non co-operation policy - always submitting everything at the last minute thus swamping the system - taking 6 weeks to answer their letters (might be difficult that as they don't reply to post anyway.) What I do , to help HMRC is copy all the papers to them with reminder letters so that at some stage they will have a storage problem.
Where I have crass stupidity from HMRC which is more and more often I copy the HMRC letters to the Chancellor of the Exchequer so that he can be aware of the omnishambles over which he presides. I assume that at some stage he might get p***ed off by this and place a kick in someone's backside ( actually I suppose that's unlikely as it will be sitting at home out of reach.)
I thought they were supposed to be Civil Servants not escapees from Putin's KGB.