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HMRC to remove agent access without AML proof

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If agents from professional bodies don’t respond to an HMRC letter confirming their AML supervision, they may lose access to online HMRC services. 

19th Jan 2022
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Accountancy bodies have alerted their members to respond to an HMRC letter with confirmation of their anti-money laundering (AML) status to avoid having their tax agent codes suspended. 

In a recent letter, HMRC called on agents regulated by a professional body (rather than directly regulated by HMRC) to complete and return a form with documentary evidence of their AML supervision. There are a number of ways this can be evidenced, such as a letter of confirmation from the professional body, for example.   

The impact of ignoring the letter is stark. Agents will lose access to some HMRC online services. Although they still may be able to sign into their HMRC agent online account.  

The Institute of Finacial Accountants (IFA) said in a letter to its members that some agents have already had their tax agent codes suspended. The IFA CEO John Edwards noted that these “firms have been unable to file any returns on behalf of their clients until the codes have been re-instated which can take five working days or more”.

How to get proof

The ICAEW's tax faculty flagged to ICAEW members that what isn’t clear about HMRC’s letter is that a letter of confirmation form must be included in the response. However, each professional body has its own form of proof of regulation.

The ICAEW, for instance, advises members to obtain this letter by contacting [email protected]. While IFA has agreed with HMRC that it’s members can use a firm fee invoice from the IFA to confirm supervision. The latest paid invoice will show the date that supervision expires. 

ACCA , meanwhile, has instructed members to provide HMRC with their firm’s ACCA ID number together with their practising certificate or copy of the firm’s OPBAS levy that was raised on the firm's myACCA portal during the practising certificate renewal period. 

ACCA has also confirmed that it’s had a couple of practitioners that have had their services turned off by HMRC. The professional body told AccountingWEB that it is supporting members to make sure HMRC has the right data.

"Glenn Collins, the head of policy, technical and strategic engagement at ACCA, advised registered members not to ignore the letter and that they should inform HMRC that they are registered with ACCA. He added, “ACCA registration is publicly available and our members know that HMRC has that information.”

“In effect, HMRC is writing out letters to batches of firms on their database rather than targeting specific agents."

Bad time to lose access

HMRC will periodically write to agents to request confirmation of regulation. But those that miss the brown envelope in January will find losing their agent access even more frustrating during the peak of self assessment season. 

“Having access to your agent portal shut off means your day to day activities and interactions with HMRC on behalf of clients are massively compromised, you can’t do work and you’re having to put things back in the position where they were before through no fault of their own,” said ACCA’s Collins.  

HMRC's statement

A HMRC spokesperson said, “All Accountancy Service Providers (ASPs) are required to be supervised for AML. To protect the integrity of the AML supervision process, there are occasions when HMRC may need to write to ASPs to confirm which Professional Body (PB) supervises them for AML (where HMRC clearly doesn’t).

“The process by which HMRC does that is to send the ASP a letter. If the business fails to engage with us by not providing the required information, we ultimately need to conclude that they are not supervised and therefore are not compliant with the law.

“This may result in the suspension of their access to HMRC online agent services. HMRC would encourage ASP recipients of this information request to reply promptly to clarify details of their PB supervision.”

Replies (101)

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Replying to jameswheelan:
ALISK
By atleastisoundknowledgable...
19th Jan 2022 12:10

jameswheelan wrote:

Perhaps they can discount my membership fees this year??!

Lol

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By bluebaron
19th Jan 2022 10:36

Haven't received any letter yet, and haven't had any warning about it from my professional body.

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By Coastal
19th Jan 2022 10:39

Take my word for it this is a nightmare - Happened to my practice July last year they said they had written letters but they were never received then boom out of the blue a letter and Self Assessment and Corporation Tax agent codes suspended. Hopefully they have sped up he process of getting them back ours took about 4-6 weeks from memory with no access to clients data and unable to file returns - couldnt call HMRC to deal with it as the agent services team dont take external calls and everyone else was clueless So had to write 3 letters (takes them a while to read a letter as we all know) and eventually make a complaint through the HMRC parliamentary complaints procedure who were great which sped up getting the codes back. All in all it was a very stressful event which i wouldnt wish on anyone so if you get the letter make it your top priority to respond. We are regulated by ACCA so just needed to print the proof of payment of the AML monitoring fees. But why HMRC cant just speak to the regulatory bodies is beyond me. Isnt that what we are paying for ?

Thanks (4)
Replying to Coastal:
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By GHarr497688
19th Jan 2022 16:39

I am regulated by HMRC. I had numerous threats that HMRC would cut me off as I was failing to renew. Last year as HMRC had not validated my renewal the link for this years didn't come up so I could not renew. I sent numerous email to so many in the AML office , I also phoned the VAT helpline who said they could do nothing. After writing to my local MP I suddenly was issued with a renewal link. How HMRC can dish out all these rules and then mess up on their side is so unfair , very stressful and totally soul destroying. HMRC should be far more accountable for how they process matters with massive penalties for inconvenience caused at market rates. I received £100 , the actual process must have cost more like £1000 in lost time plus all the worry associated.

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LL
By RickyRoark
19th Jan 2022 11:03

I'm curious to know how HMRC arrive at these policy positions.

Is their thinking really as simplistic as "If all the accountants are registered for AML, then there will be no more money laundering"?

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By JD
19th Jan 2022 10:42

Once has to wonder how many former HMRC staff and inspectors (from all those office that closed) and book keepers, who are ''just helping out'' will be caught by this ?

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By janelm
19th Jan 2022 10:54

Letter arrived 10th December, dated 3rd December, giving me just 30 days to reply or my agent codes would be cut off. Literally says "If you are uncertain what evidence to provide, please check with your supervisor".
I immediately contacted ICAEW who will "respond within 10 working days", I phoned ICAEW to check I had emailed the right dept (I hadn't, the operator kindly forwarded it).
I thought for a while as to what could be considered 'proof' and sent a letter back to HMRC same day with my ICAEW invoice showing as paid (though only to 31/12/21 because subs were just about to renew in Jan) and said I'd asked ICAEW and I would forward further info in due course, and complained bitterly about the 28 day deadline. ICAEW responded quicker than 10 days and I forwarded their letter onto HMRC. I don't seem to have been cut off so hopefully the letters made it (I asked for confirmation of receipt but doubt they'll bother). I didn't send registered as I've heard this can take longer to reach the right dept (not sure if that is true).
Would advise asking ICAEW for the letter in advance so it is ready to go if HMRC ask, and/or would be useful if ICAEW issued us with these annually as standard. If I had had to wait 10 working days from 10th December with holiday season it would seem there was little chance that my response would reach HMRC in the arbitrary too-short time limit. (Never been asked for anything from HMRC since I first set up agent codes 17 years ago).

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Tornado
By Tornado
19th Jan 2022 11:00

SECURITY DANGER - WRONG AGENT ADDRESS

I moved office about two and a half years ago and advised HMRC of the change in writing. This is related to my online services and I have written to HMRC two more times since and nothing has changed. Changing address details with HMRC cannot be done online or on the phone and if they decide to send confidential letters to my old address, then such correspondence will not get sent on to me and could easily be read by anyone.

It is disgracefully woeful that HMRC are unable to deal with basic matters but still push ahead with fanciful projects that are unlikely to succeed. They have no sense of priority at all.

Fortunately (and rather mysteriously) they do have the correct address for my Agent Services Account, yet another example of their disgraceful approach to security of Data.

EDIT : The foregoing was correct until very recently but I have just checked today and the address has now been changed. This gist of this post is still valid, however, as it has taken HMRC nearly two and a half years to make the change and may serve as a reminder to others to check that their details with HMRC are correct.

Thanks (7)
ALISK
By atleastisoundknowledgable...
19th Jan 2022 11:01

Erm … ACCA haven’t sent me a PC for about 3 years. (And yes, I bloody well do pay).

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Replying to atleastisoundknowledgable...:
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By Hugo Fair
19th Jan 2022 11:04

Maybe they do ... just not to your address (taking a leaf out of the HMRC playbook)!

Thanks (1)
Replying to atleastisoundknowledgable...:
Kitten
By Hazel Accounts
20th Jan 2022 10:29

I think they've stopped posting them - you can download from "myACCA"

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By harpsong
19th Jan 2022 11:07

I had all my agent access removed because of this. I had replied to HRMC with the information ACCA told me to. A few months later I found I had no online access to any of my clients anymore. Seems HMRC just didn't read the letter as it was in a pile with the other 5 million letters they hadn't opened yet.

It took emails all over the place and complaints to get my access back. I was without access to clients for 3 days, which in hindsight isn't so bad. But at the time I thought it was going to be months until HMRC sorted it out. Initially, they were telling me to send a complaint in writing which would have a target date for an initial reply in 12 weeks!

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By cfield
19th Jan 2022 11:08

I got one of these letters last week in response to a 64-8 we'd sent in. It was a bit confusing as the heading was about a change to our agent codes. I filled out the form and sent it back with short shrift comments about them already having this information. I wasn't sure what to give them as proof, so enclosed a copy of my last paper ACCA certificate from 2019, told them they don't send paper ones anymore but that they can look me up easily on the public area of the ACCA website.

Given how long it takes them to deal with correspondence now and reading the comments above, I'm a bit concerned now that they might switch me off without any further warning.

The simple answer of course would have been to get lists of practising members and marry them up to their agent records, but there would have been IT issues for sure. Nothing beyond the wit of man though with a bit of planning and foresight. They are clearly oblivious to the concept of "exception reporting".

Perhaps they're sorting the sheep from the goats in preparation for bringing in a two-tier system for agents, but more likely it's another box-ticking exercise (Verified agent supervision? Yep, done that). They would be better employed carrying out their own supervision duties more effectively rather than just raking in the fees and doing very little. There's not much point in having a law that says all agents must be supervised if no proper supervision takes place. Last year I had to complete an AML questionnaire for the ACCA. Do HMRC make unqualified agents fill out questionnaires?

Thanks (4)
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By paul799
19th Jan 2022 11:11

We had this issue in June 2021 but the letters from HMRC never arrived so like others the first we knew was when our access got restricted.
Does anyone know if this is going to be an annual event or a random one as and when HMRC think about it? The sensible thing to do would be to say it was annual and everyone has to do it in June but i don't suppose that is going to happen!
For safety I am tempted to ask ICAEW for their usual letter and just send it to HMRC anyway.

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By tanyajackson
19th Jan 2022 11:38

Why don't they just add a page to agents services called AML, with a message to direct you there when you next login. You can then upload and provide the information being asked quickly. Why waste all the paper with letters (that never arrive) and man hours to open and check our posted responses.
It can renew each year so you can just upload every 12 months.
The mind boggles.

Thanks (8)
By Moonbeam
19th Jan 2022 11:39

I have been seriously wondering whether to plough on, with decreasing client numbers and difficulty finding more.
This post may hasten things somewhat. I've been horrified to read of others' experiences, but not been warned about the letters by ATT, my own body.
God bless Aweb and the excellent people who post on here. I'm sure I should be paying a sub to Aweb just to keep me informed of this and similar nasty things I need to watch out for.

Thanks (6)
Replying to Moonbeam:
Scooby
By gainsborough
19th Jan 2022 13:57

I second the above thanks to all the Aweb posters. Have heard nothing from the CIOT and can't see anything on their website mentioning this. No letter received from HMRC either....

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Replying to Moonbeam:
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By Catherine Newman
19th Jan 2022 14:04

I'm CIOT and I haven't had one. Are they going through the PBs systematically or just some PBs.

Timing sucks.

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Replying to Catherine Newman:
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By IanClark
20th Jan 2022 12:28

The "trigger" appears to be moving address, most I have spoken to who have gone through this have moved in the prrior year.

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Replying to IanClark:
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By Catherine Newman
20th Jan 2022 13:57

That is really interesting. Thank you very much for letting us all know.

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Replying to Moonbeam:
By cfield
20th Jan 2022 11:51

Moonbeam wrote:

I'm sure I should be paying a sub to Aweb just to keep me informed of this and similar nasty things I need to watch out for.

Don't give them ideas! Actually they should be paying us for contributing to the site.
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By SXGuy
19th Jan 2022 11:43

5 working days lol someone stop me from falling over laughing please.

Will they write to people who don't have a professional body and isn't registered with hmrc for aml? How does that work?

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By ireallyshouldknowthisbut
19th Jan 2022 11:48

Checking Agent Address Held

SA - "about your firm" under the SA tab where the list of clients are. You can amend.
CT - "about your firm" under the CT tab where the list of clients are. You can amend.
PAYE - ..........
VAT - ............

Anyone help with the final 2?

Thanks (1)
Replying to ireallyshouldknowthisbut:
ALISK
By atleastisoundknowledgable...
19th Jan 2022 12:12

ireallyshouldknowthisbut wrote:

Checking Agent Address Held

SA - "about your firm" under the SA tab where the list of clients are. You can amend.
CT - "about your firm" under the CT tab where the list of clients are. You can amend.
PAYE - ..........
VAT - ............

Anyone help with the final 2?

Thanks. Pretty sure VAT is impossible due to their systems.

Thanks (0)
Replying to ireallyshouldknowthisbut:
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By SXGuy
19th Jan 2022 14:11

Vat is impossible without sending new 64-8s I believe.

Paye you have to write to agent maintainer with every paye reference from what I gather.

I haven't bothered with either of those though.

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Replying to ireallyshouldknowthisbut:
ALISK
By atleastisoundknowledgable...
20th Jan 2022 09:48

Any idea how you amend?

I'm looking at SA, the address they have is 4 offices ago and says "HM Revenue & Customs has been unable to deliver mail to you. Please update your address." But no link etc to change address. Jeez Louise, could they make this tougher?

CT is the correct address

Thanks (1)
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By Andrea plaw
19th Jan 2022 12:09

This happened to me, never received the letter but luckily i managed to resolve via phone and email very quickly rather than have to send letter to agent maintainer. clients were not there when regain access but online services resolved as they keep a back up list. also had to change address way before this which was a pain but finally resolved. i have spoken to manager in the dept and said should do a reminder letter before just remove access as post does go missing.

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By Andrea plaw
19th Jan 2022 12:09

This happened to me, never received the letter but luckily i managed to resolve via phone and email very quickly rather than have to send letter to agent maintainer. clients were not there when regain access but online services resolved as they keep a back up list. also had to change address way before this which was a pain but finally resolved. i have spoken to manager in the dept and said should do a reminder letter before just remove access as post does go missing.

Thanks (0)
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By Andrea plaw
19th Jan 2022 12:09

This happened to me, never received the letter but luckily i managed to resolve via phone and email very quickly rather than have to send letter to agent maintainer. clients were not there when regain access but online services resolved as they keep a back up list. also had to change address way before this which was a pain but finally resolved. i have spoken to manager in the dept and said should do a reminder letter before just remove access as post does go missing.

Thanks (0)
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By Mr J Andrews
19th Jan 2022 12:30

Imagine - being in this invidious position owing to HMRC's latest 'requirement' - educating a large number of clients to provide information in good time to meet the initial filing deadline with paper Returns. Processing time anyone's guess.

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By adam.arca
19th Jan 2022 13:57

I read this article and my first thought was a resigned shrug of the shoulders "c'est la vie," yet another example of HMRC fiddling whilst Rome burns / moving the deckchairs whilst Titanic sinks.

But, actually, this is an outrageous snub by HMRC of all our professional bodies and their AML supervision authority. If they're going to be cut out of the loop like this, then we might as well all be supervised directly by HMRC (*shudders* at the prospect) and cut out the middleman.

Thanks (4)
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By Catherine Newman
19th Jan 2022 14:08

I thought that too. HMRC may be looking to get a source of Revenue or they may not be so rigorous as the PBs. They are clearly over-resourced if they can do this.

Thanks (2)
By Nick Graves
19th Jan 2022 14:46

I've had too many (reliable!) clients swear blind that they've not received an alleged letter from HMRC.

Bet the same is happening to beancounters too.

Unless the whole of HMRC is being run by utter S4Bs, the January timing has to fall on the 'malice' side of Hanlon's Razor. More evidence of 'controlled demolition'?

Thanks (1)
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By Ian McTernan CTA
19th Jan 2022 16:00

How stupid this system is.

Why isn't there a registration database?

Why can't the supervising bodies provide this information direct to HMRC?

Why hasn't my Institute sorted this out- it's not exactly cheap to pay for AML from CIOT????

What a farce.

Thanks (7)
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By CatsandDogs
19th Jan 2022 16:16

I had this letter several months ago. We are supervised by HMRC but i had to fill out a lengthy form to tell HMRC that they were supervising us themselves and it would be helpful if they could join up their systems - with the requisite level of sarcasm.. Haven't heard back so assume they are back under their rock..

PS - took us 3 years to get our address changed on all of their systems - still get the ocassional rogue letter...

Thanks (4)
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By flightdeck
19th Jan 2022 17:05

This is one of the most dispiriting set of comments I have read. HMRC should read them and take a wake up call. Your collective experiences are shocking and too numerous and consistent to be dismissed as just an edge case. Things are not good in UK PLC.

Thanks (3)
the sea otter
By memyself-eye
19th Jan 2022 17:43

Ohh I'm so pleased (and smug) I've left all this behind.
still waiting though from a visit from -
a) MLR police
b) GDPR Gestapo
c) Canal and River Trust for starting my boat's engine while moored.......

How does one pronounce F'off?

ps: I made c) up.

Thanks (1)
Replying to memyself-eye:
Pile of Stones
By Beach Accountancy
19th Jan 2022 18:39

Re (c), given their green agenda it's only a matter of time... anybody got £10k to convert my 2 litre 1975 petrol motor cruiser to electric?

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By Wycher
19th Jan 2022 17:57

Could someone post a copy of the letter and form up so we can see what to expect?

Thanks (1)
By ireallyshouldknowthisbut
19th Jan 2022 18:09

This is HMRC's world leading digital tax system in action.

It cant check two databases and generate a query list, but relies on contacting everyone and what sounds like a huge laborious manual process which falls over at the first hurdle of using out of data addresses.

there also seems to be zero attempt to contact any firms they don't here back from directly using other data they hold for agents such as their phone number, emails or a quick google (ie 5 minutes) but instead is happy to waste hours and hours of something else's time getting them put back on.

Chartered Institutes and member bodies, please get stuck in. This is what we pay you to deal with. Get this suspended until HMRC design a proper system.

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By Paul D Utherone
19th Jan 2022 22:05

I seem to recall getting such a letter a couple of years back now. Not seen anything so far this year.

And I thought that any new agent trying to get set up with HMRC Agent Services had to prove this as a matter of course now. No supervision, no Agent account

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By creamdelacream
19th Jan 2022 22:28

We've had a few of these letters and luckily HMRC have opened our responses and not suspended our account. We had the same address problem for a few years and have been relying on mail redirect. Hopefully they will have updated the address before the redirect ends.

This is how an organisation is run when there is no accountability, incentives or consequences. Good old public sector hey.

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x
By rockallj
20th Jan 2022 01:43

Oh dear, seriously worried now.
No letters arrived. I've changed address recently, managed CT online.
Letter to HMRC for other taxes still not answered.

When I moved premises 10 years ago, it took 2-3 years and several letters before this was finally changed. The system stinks.

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By ASF
20th Jan 2022 11:35

I have been qualified with one of the main professional bodies for 30 years, and have considered hard whether or not to resign my membership of it, as I now approach state retirement age, and before I saw this article and thread, had already pretty much decided that this year will be my last as a "qualified" accountant. The few people who I work for, on occasion, know my background, qualifications and experience, and if they feel they want my help, reach out. Those who, don't matter to me, as potential future clients. I neither want nor need them, despite much of platforms like LinkedIn telling me how wonderful it is to master LI "marketing" and selling. Personally, I see it as a great big pile of horse dung, but I do understand, to some folk, it is the be-all-and-end-all of how to secure business in this modern world.
Reading this latest string, just reinforces my view that this year will be my last for membership of a professional body (that, as someone said, makes a complete and utter mystery of what it is that they might ACTUALLY do for me), and I will take my chances, alongside all those people who are unqualified and (largely, it seems) unregulated, at least knowing that I know most of what I need to do.

We have all seen ever-increasing levels of control and regulation trundling along in our direction for years, like a steamroller that has lost it's steering wheel and brakes, and thus can only head one way, and I feel now is the time to get out. I will spend my later years working with, and helping people I want to help, but I am damned if I am going to spend time, effort and money (on things such as CPD) dealing with the ever-increasing bureaucracy the profession and government throw at us, whilst steadfastly refusing to give professional accountants legal recognition, just because governments are largely run by (legally-protected) lawyers, who have raised them drawbridge around themselves! "Arrividerci Roma", as someone once sang.

Thanks (3)
Replying to ASF:
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By Red1960
20th Jan 2022 12:47

Well, said.

I can see no benefit to membership of any Prof Bod save the actual qualification bestowed on entry.

There is a reason that HMRC, as a body, treats the profession, its members and taxpayers with such a level of self evident contempt and that is quite simply because it can, with absolute impunity.

They are, in a word, unaccountable. When was the last time you had a complaint taken seriously by HMRC without getting an MP involved? Why is that PAC has no sanctions available to use against HMRC which in turn regards it as a minor inconvenience?

The last thing that HMRC wants is to be made transparent in its dealings and that is the first pre-requisite for accountability.

When you look at the revolving door between HMRC and the top of the profession (who control the prof bods) you have to wonder whether this is a healthy situation particularly for the rest of the profession but also the general public who are kept pretty much in the dark about this although they are victims of it just as much as we are.

Quite a gloomy outlook for the forseeable I'm afraid and not much of an incentive for those considering entering a profession with a declining status and reputation amongst the general public.

HMRC will do what it can to hasten that process and you'd better believe it.

Thanks (2)
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By Jekyll and Hyde
20th Jan 2022 12:48

So there is no section on the agent services dashboard to enter and supply details for this! But they will take away the facility of agent services dashboard.

Surely the easiest thing to do is to have a link in the agent services dashboard, where agents can fill this and upload evidence within the agent services dashboard, or am I just being stupid?

All those trees being wasted and costs to outsource the postage of letters. I had a client ask me if HMRC still send out statements!! his guess was as good as my own.

Thanks (1)
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By Jekyll and Hyde
20th Jan 2022 12:48

So there is no section on the agent services dashboard to enter and supply details for this! But they will take away the facility of agent services dashboard.

Surely the easiest thing to do is to have a link in the agent services dashboard, where agents can fill this and upload evidence within the agent services dashboard, or am I just being stupid?

All those trees being wasted and costs to outsource the postage of letters. I had a client ask me if HMRC still send out statements!! his guess was as good as my own.

Thanks (1)
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By copperfield.21
21st Jan 2022 11:46

I have nor received a letter, so do I have to do anything

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Replying to copperfield.21:
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By Hugo Fair
21st Jan 2022 18:20

It's not a matter of whether you've received a letter ... merely a matter of whether HMRC say they've sent one to you!

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By Revels1
21st Jan 2022 15:17

It's remarkable they have the ability to do this, but cannot change the agent address linked to these agent codes for VAT and PAYE. When we moved offices, they told us we would never be able to change change our agent address for those taxes and our only option was to register as a new agent and transfer 100s of clients across. We've literally sent people to the moon, but it's beyond HMRC to change an address in a system.

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