MTD ITSA: What will it all cost?
Wendy Bradley pulls apart the policy documents on the costs and benefits of MTD ITSA and discovers some astonishing assumptions leading to quite unbelievable conclusions.
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Hi Wendy,
This is a good article and summarises well everything most of us working in accounts feel/suspect/knew already.
The burden put onto the lower end of the market is going to be horrific. Even the simplest of things is bringing in issues, like moving a manual client and their Collins book to an identical copy on Excel for MTD for VAT.
The delay for one year is not unexpected but it really needs a whole rethink.
Cheers!
The most fundamental flaw in the 'justification' figures (even before we get to ludicrous optimism and downright obfuscation) is the disjunct between:
* revenues flow every time, but
* costs only occur once!
The cost of 'going digital' isn't just buying the hardware and licences (or indeed in trying to get it all to work) ... but in keeping it working when Microsoft update the operating system or Google change Chrome or ... (insert suppliers of choice).
In exactly the same way that 6 minutes of work by an Agent doesn't happen in a vacuum ... you have to clear your mind, find the salient records, review them, note potential anomalies and then (after potential interruptions on behalf of other clients) chase the client for missing/corrective data, get it amended (or do it yourself), re-review to ensure you don't need to repeat any of these actions and submit a return which may only contain a few figures. Oh and then keep an eye open for whether HMRC actually acknowledge receiving the submission!
That is a simplified list, but I'd like to see any of the appropriate civil service mandarins carry them out (even with dummy/incorrect values) in the 6 minutes ... and then try to do it again and again and again, whilst the phones ring and the emails ping - knowing that HMRC are standing by ready to support their 'customers' by blaming them.
Wendy, most Accountants of a certain savvy would already have poo pooed quarterly updates as soon as they were mentioned. Experienced Accountants know what the time and money cost is without dissecting documents. Mind you you're spot on they are a giggle. Problem is the people that matter will believe it. Where do the people come from that write this sort of nonsense?
Good news then
I can tell all my worried clients that they can ignore MTD
That will take a lot longer than 6 minutes per person though. If it were 6 minutes and each only had one submission, so no traders with rent income, a mere 20 hours, assuming no gaps and interuptions and no coffee and no misdialling or being sociable or dealing with ANYTHING not attributable to the six minute window
I'm afraid this is another example of an attempt to mislead Parliament. It is common practice to drastically understate costs to get a project approved, then by the time the true picture emerges, it is too late to turn back.
Parliament was told that HS2 would cost £55 billion whereas the true cost will be north of £200 billion, and due to increased remote working, the previous assumptions regarding job creation now look absurd.
But that does not excuse the ICAEW failing to shout loudly that MTD is a complete farce and should be abandoned immediately. I think the Institute supports HMRC more than it supports its own members.
NOTHING takes just six minutes. It can take that long to locate and open the files and read up any comments from a client. That is before we start to look at numbers and before we start to ask for clarification of numbers. HMRC is making the case for MTD by pedalling untruths.
First rule of project promotion - lie about the benefits, closely followed by rule 2 - understate the costs, then rule 3 - ignore the problems.
I do not see four quarterly reports increasing workload by x5, as some have said, but certainly expect at least a doubling of work for the smaller clients. The three hour a year once-a-year jobs will consume six or seven hours.
'First rule of project promotion - lie about the benefits, closely followed by rule 2 - understate the costs, then rule 3 - ignore the problems'.
... alas Classic HMRC behaviour as they unveil yet another 'dogs dinner'.
From my time in HMRC the only winners were outside IT consultants, HMRC heads and senior staff who see initiatives like this as promotion opportunities, who quickly move onwards and upwards leaving devastation in their wake.
Thereafter both HMRC staff and business struggle for years to come with the new IT 'wonder system'.
They can do it themselves for our clients for £6 per quarter - but don't expect us to do it for such a ridiculous amount.
Thanks Wendy, excellent article highlighting the obvious cost/benefit skewed view that HMRC have on MTD ITSA.
MTD VAT was sensible, but the reality is with MTD ITSA the group of taxpayers that it affects is so vast from a computer illiterate granny with rental income (above £10k) and state pension to a high earning tech savvy self-employed consultant. The cost/time spent will be highest for the smallest clients and lower at the other end. We are going to be forced to increase fees for the lowest earners, whose lives will not be made any simpler/easier taxwise as they will genuinely take most of our time for all the reasons you have mentioned.
The £10k threshold is simply too low and they need to introduce MTD ITSA in a more staged fashion like they did for MTD VAT (over £85k first in April 2019 and then under £85k 3 years later in April 2022). We had time to embed this, but MTD ITSA is a sweeping blow that does not look at cost/benefit at all and will undoubtedly increase the tax burden and cost for the smallest of clients.
The software houses have already mopped up the MTD for VAT market so MTD for ITSA for businesses with turnover above the VAT threshold would not be worth them getting out of bed for. It is the lower end of the market that is now the untapped and huge potential for the software houses. That is what they are primarily targeting and using HMRC as the big stick to ensure the pool of potential customers remains at a sustainable level for them to feed off. It makes far more sense to push MTD for ITSA out to the larger businesses first as they will already have MTD for VAT compatible software in place and the move on to MTD for ITSA will be a progression from that. Larger businesses are more likely to have the capability and resources to deal with it and should be able to iron out a fair amount of problems before the next phase is released. However, this would not bring in enough new customers for the software houses hungry for increased market shares.
My sentiments exactly, posted something similar earlier today at https://www.accountingweb.co.uk/community/blogs/kevinringer/mtd-itsa-won....
Excellent article, just the reality. RTI has not worked after so many years. Who in their right mind thinks MTD ITSA will work. How many accountants have been able to retrieve client's salary and pension information from the HMRC within 6 months. It should be available within 2 days. 5 April 2021 information is not available to date. What is their excuse. A form P60 and P45 not fit for purpose. Inadequate information of NIC, student loan deductions on P45, Auto-enrollment contribution figures not available on both P45 & P60. With multiple jobs and self-employed income, overpayment of NIC not resolved long after self assessment returns filed. Interaction between tax and NIC very poor. One can see that submission will not be possible, without ticking a box stating 'information is true and correct'. Only option will be to find a white space to include a disclaimer for accuracy of information. Has anybody got a refund for tax over-payment following a reduction in liability in a subsequent RTI submission or under quarterly CT instalment payment scheme. It should be paid back automatically. We are in this sad state because professional bodies do not challenge the HMRC.
'One can see that submission will not be possible, without ticking a box stating 'information is true and correct'
I remember in the early days of Self Assessment there was a box included which had to be ticked to say that no estimates were included in the Return. As reasonable estimates are often used to compile some data for the Return, those of integrity would tick the box even if it was related to a few pounds estimate of building society interest.
I was never contacted about this but I guess HMRC were inundated with ticked boxes where other people were doing the right thing and they clearly could not deal with so many trivial estimates. That question has not been asked for many years now.
So HMRC need to be careful about what they ask for.
Argos sell a £200 laptop, https://www.argos.co.uk/product/9197048?clickPR=plp:28:269
Looking at those specs, it'll probably take 6 minutes just to boot to a desktop.
Who on earth at HMRC comes up with such garbage!? Clearly no one who has ever had any close experience of completing accounts or tax returns, especially for small businesses that do not have a handy IT dept to pass it all on to! Did HMRC consult sufficiently widely with relevant parties in arriving at their 'risible' conclusions (ie us lot - not just the software suppliers)?
In the private sector heads would roll for such poor quality work. This is just one of so many current issues demonstrating how out of touch HMRC decision makers are from the real world. If they were bothered to do so there are enough volunteers (I for one) who could show them what HMRC dross we come up against regularly, away from their London ivory towers. No doubt HMRC senior execs (retiring at 60 with gold plated taxpayer funded pensions) will still get a 'well deserved' gong in the New Years Honours!
In the private sector heads would roll for such poor quality work.
Thanks for that... almost as funny as the MTD fantasy that afflicts HMRC.
'female senior HMRC officers' 'these silly women'
Inference in your post is that all would be OK if the job had been given to men.
I must say I am not convinced about that. Or maybe I am reading too much into misogynist language?
You are KNOWINGLY looking for a problem that is not there
Is it a fact that they were women?
Is it a fact that they demonstrated sillyness?
Many thanks, Paul and of course you are totally correct.
Unfortunately, the Civil Service is riven with women promoted above their level of competence only because they are women. Political Correctness gone mad, I fear.
I have worked with many really able ladies and sing their virtues to the roof: there are many who demand praise, for example, Dr Ros Altman, Baroness Susan Greenfield to name but a couple.
"Six minutes"
I retired last year (after 50 years in accountancy) and can laugh without having to worry about how this is all going work....
Great article btw.
I'm retiring too and have managed to find a colleague willing to take on my clients but how many taxpayers (sorry, customers!) will be forced to go to larger firms or will try to deal with this themselves?
The six minutes guesstimate reminds me of when I took my exams many years ago. We were allocated something like 20 minutes to read and answer complicated questions, which I thought was totally unrealistic in the real world, where I would take the time to undertake research and possible ask more questions. Needless to say I failed the exam because I ran out of time. How often do we pick up a job now, thinking it can be dealt with straight away, only to find that there is information missing or queries to be answered!
Excellent and informative . This needs exposing before we all fall in the trough . The single biggest factor that HMRC / government appear to be missing is :
1. The willingness of clients to use software.
2. Their capability to use it.
3. When they ignore it / refuse to use it / are not technically minded and simply do not know how to use it ... who sorts that out ?
4. Will clients pay extra ? Doubt it .
They should stick to once a year as anything else will just be a complete and utter mess
As Peter Schiff's latest episode is titled: "Government Creates Problems. Its Solutions Make Them Worse"
I hate MTD, but I'm glad we have a government that does things for its citizens. If Peter Schiff had his way we'd be copying the American model of healthcare and our country would be far worse off for it.
Governments get a lot wrong, but the private sector isn't a panacea for every problem.
I hate MTD, but I'm glad we have a government that does things for its citizens. If Peter Schiff had his way we'd be copying the American model of healthcare and our country would be far worse off for it.
Governments get a lot wrong, but the private sector isn't a panacea for every problem.
I agree that the private sector isn't a panacea for every problem, and respectfully disagree that we'd be "far worse off for it". Just because the costs of the NHS are not explicitly visible in NI contributions and taxes, doesn't mean we don't pay a large amount for our health care. From the gov's website: In 2017, spending on healthcare in the UK totalled £197.4 billion. This equates to approximately £2,989 spent per person, or 9.6% of gross domestic product (GDP). Nurses and doctors are overworked, waiting times through the roof. Definitely not the best system in the world.
When we have a straight faced Mr Johnson, unkempt and all, tell us how great and lifting future prospects are, with obviously little attention to the long term effects of the fragility of the country's finances and services, it is not surprising that the not unconnected HMRC take the same shallow out of touch view of the prospects of MTD.
One step at a time towards its launch and as we get closer HRMC will have to rethink and put better resources in place to make MTD work or they will have to prepare for the serious aftermath that will follow.
Very good Wendy and yes, I have to laugh. You have actually only highlighted just a few of the ludicrous faults with the MTD Project
In fact I have been laughing at MTD for some time now as more and more ridiculous aspects of MTD are revealed. It is now so addictive that I cannot wait for the next instalment to be revealed.
To me, MTD is like one of those cars that Clowns use where it looks like a car but everything falls off when they try to use it.
If HMRC are estimating the costs to people of implementing MTD in this way then by applying the same principles to their own costs of developing MTD we should by now have a fully working, world beating system and much, much more for the 2000 million pounds that has been allocated/spent on this project. It would be interesting to see how they have costed their own development of this project. I doubt if anything at all would be costed at 6 minutes.
So far as I can see, everyone seems to be assuming that you would have to prepare and submit the four quarterly reports with real figures derived from primary records in what would essentially be four additional in-year sets of accounts.
Why?
The previous thread on MTD ITSA pointed out that the quarterly reports would not determine a taxpayer’s liability, and that there was no connection between these and the yearly submission which will mirror the existing tax return schedules. So I see no reason why the quarterly reports could not be populated with estimates. So long as they are received on time, there would be no comeback.
In which case it might very well take no more than 6 minutes per return.
Or have I misunderstood?
You're totally correct. So let's take that a stage further. There is no point in quarterly updates which is what we have been saying ad infinitum.
HMRC have been quite clear that the quarterly reports have to be based off actual transactional data (e.g. till records, money in/out of bank account), not estimates. They have also said that they may check into final returns wildly off from the 4 returns added up. So it's a risk you take if you estimate things based on no underlying book-keeping data should the inspector ask to check workings!
HMRC have already said that to start with they are not particularly interested in the figures, just that they get business used to preparing on a quarterly basis. The true content will come later. Can you see HMRC checking thousands of workings? Not on your nelly.
Frankly, I’m hearing different things from different people, so it’s hard to separate fact from fiction. But if they do insist on four additional interim quarterly reports based on actual data with one month time limits, then that will be next to impossible to deliver.
If you can set up the estimates and report in six minutes, well done you
It takes my staff longer to file either dormant accounts at Co house or a no payment Wages submission
Assuming that they have not prepared and opened any software and assuming they record the work as having taken place
Response to whiteways
If you go down the route of assuming no relationship between MTD submissions and year-end accounts and everything will get tidied up with the final submission, why waste time and money with the four quarters in the first place
I am still waiting to hear EXACTLY what information has to be provided quarterly and how it is to be calculated (e.g. receipts, payments, debtors, prepayments, creditors, accruals, private use adjustments, stock, wip?). We have been told, I think, that capital allowances and disallowable expenses do not have to be calculated. Some businesses elect for cash basis, others do not. Some businesses just keep cash book records and a bundle of unpaid invoices. Others may have sales, purchases and nominal ledgers. Some may even have automated stock / wip records while others do a stock-take or calculate recoverable wip once a year. If just reporting total receipts and payments analysed under a few headings (per SATR) it cannot be very onerous. If it requires a full set of management accounts produced under FRS / UKGAAP, it will be a major task.
Tony, initially the detailed specs said we'd need to transmit the P&L and Balance Sheet in the same level of detail as the SA103, though no stock, accruals and prepayments. I don't know if that's still the case because I've given up being concerned with the detail now that the wider picture is such a joke. I'm increasingly convinced it won't happen.
Great article and I agree with most of what you say. However, there is one area that HMRC may have accurately estimated the timing and that is on "filing" the quarterly summaries, but I make a big assumption in allowing that this may be so.
If HMRC truly just want us to click a button once a quarter from within MTD-compliant software to show that the tax payer has 'gone digital', then this will, indeed, only take 6 minutes (or less). That relies on zero checking of the data, which may be fine for HMRC, as they have already confirmed (as announced by Rebecca Benneyworth) that they do not need any adjustments made to the basic data each quarter (so no accruals, prepayments, stock adjustments, etc.). If the client links their software to their bank or uses a bank account that can itself file MTD data (eg Countingup and probably Starling and the other disruptor banks by 2024), then I am presuming that a simple button-click will suffice, if there is no need for the bank to have been even reconciled in order to be MTD-compliant. As accountants, we will then do our usual year-end work, as before, but with the benefit that at least the basic data is already in a digital environment.
This process would only prove to HMRC that the taxpayer is using digital software (as unreconciled data without accounting provisions does not present anything like an accurate picture of profit) and many accountants out there will complain that this is, therefore, pointless. However, I see value in encouraging taxpayers to go digital (though a threshold much higher than £10k pa would make far more sense). As a first step in a long term goal that will, no doubt, eventually require more than just unadjusted data, this seems a reasonable start for a noble aim. BUT, HMRC need to confirm that the QUALITY of the in-year data is irrelevant as it is PROCESS that they are checking, not accuracy.
Unlike MTD for VAT, no tax calculations or payments are made based upon in-year submissions, so accuracy should be totally unimportant and HMRC have already (in part) confirmed that. However, if HMRC require the data to have any accuracy, then the 6 minute estimate is a total nonsense.
I've looked at quarterly updates all ways, even looking at it from HMRC point of view. My conclusion is that it won't work, is pointless and doesn't do what it says on the tin. I'm in agreement with Kevin that HMRC will pull the plug on it (for the time being).
It should, on that basis, take no time.
If no involvement then client could learn on day 1 the button to press
The nonsense is that any agent can do anything worthwhile in 6 minutes
EVEN WORSE the expectation that a job can be validly sliced up into 5 parts and cost the same
£250 plus VAT start point for a simple job becomes 5 reports at £50 a report and the time stays the same?
No it does not
If we do the bookkeeping for VAT we charge more than if we do not
What about cash sales not banked and used for cash expenses and also contras?
With many small businesses there is still a good mixture of sales methods not all bank related.
There are so many side-splitters in https://www.gov.uk/government/publications/customer-costs-and-benefits-f.... An example:
"This table presents the average estimated additional hours of agent help to assist with MTD transition.
Record keeping journey Number of hours of agent help
From paper to software 10
From spreadsheet to bridging or MTD software 5
From software to MTD upgrade 5"
I did convert Joe the Plumber (his name has been changed, but he is a plumber) from paper to software. He never got the hang of it. He's employed someone to do it for him. They do a good job of it but it took about 50 hours over 12 months to get them to the level of competency where I could rely on their accuracy, and I need to spend about 20 hours a year ongoing dealing with less-common transactions (eg buying a van on HP).
Sounds like my builder client who bought QB without talking to me then took on a bookkeeper who had never used it and so needed training (from me of course). I had to check the figures every VAT quarter and correct the mistakes before the returns could be filed (definitely more than 6 minutes work!).
I didn't actually sack him but used my impending retirement to persuade him to find someone else.
If we are supposed to do everything quarterly in 6 minutes then surely it's not beyond HMRC to actually answer a simple letter in the same time.
If we are supposed to do everything quarterly in 6 minutes then surely it's not beyond HMRC to actually answer a simple letter in the same time.
Even 6 months for HMRC to answer letters would be nice.
Another thought .. your client is VAT registered but their stagger is not the same as for self assessment MTD . So you might consider changing the VAT stagger . Problem then is all clients have same stagger and workload becomes unmanageable. Or are HMRC allowing for this and will allow non 5th April / 31st March aligned year ends / quarterly returns ? Just a thought
Too much spent on it already and too much loss of face, I guess. But I agree - can the whole thing.
Can I have the name of store that sells £200 computers? Whilst at it can we have the name of the free software provider. Oh and can HMRC please (!!) answer their phones, actually answer the question posed to them (Following law not their wishful thoughts). That should take 6 mins in total.
Not laughing at all but crying. Convinced they are on drugs.
I now see someone posted that Argos sells £200 laptops. OK good luck with that.