Lords slam Making Tax Digital rollout

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A Lords committee has called for a delay of at least one year to the mandatory rollout of Making Tax Digital for VAT, asserting that HMRC has neglected its responsibility to support small business and claiming costs will be far more than the government’s impact assessment.

In an excoriating report published today, the House of Lords Economic Affairs Committee laid out its concerns about the impact of the government’s Making Tax Digital for VAT plans.

The committee called for a delay of least one year for the government’s digital VAT regime, currently scheduled to roll out in April 2019. It also asked for a “staged transition” for businesses joining MTD for VAT, and requested that the government wait until at least April 2022 before extending the scheme to other taxes to learn from the VAT implementation.

Criticisms levelled by the Lords included low levels of awareness from affected businesses, the cost of MTD compliance, difficulty in navigating the software market, the justification for the programme and the underlying assumptions behind it.

However, the report did miss the mark on several key points, including the availability of free software and the reason for the delay in mandation for more complex businesses.

Small businesses ‘will not be ready’

Each year the Lords Economic Affairs Committee appoints a Finance Bill sub-committee to inquire into the draft Finance Bill, and this year the committee decided its inquiry should address two areas: progress on MTD and HMRC powers.

Among the most damning assertions in its MTD report published today, the Lords stated that HMRC has “neglected its responsibility” to support small businesses with Making Tax Digital for VAT

Commenting on the report Lord Forsyth, the commission’s Chair said the tax authority is “not listening” to small businesses.

“Small businesses will not be ready for this significant change to their practices if it is introduced on 1 April, particularly with Brexit taking place three days earlier,” Lord Forsyth told AccountingWEB. “The government must delay its introduction.”

The committee stated that HMRC was “alone in its confidence” that all one million mandated businesses will be ready by April 2019 and although the tax authority has now begun to step up its awareness campaign, with less than five months remaining before introduction the Lords felt it was too late to begin an effective communications drive.

Responding to the report an HMRC spokesperson said: “We are disappointed that the committee’s report doesn’t reflect HMRC’s wide and significant engagement on Making Tax Digital (MTD) over the last 3 years, nor the changes made as a result for small businesses.

“HMRC has already written to 200,000 businesses and will be writing to every other mandated business in the coming weeks to ensure they know about the changes and how to prepare.”

Digital exemptions guidance 'a matter of urgency'

The committee, which took evidence from HMRC, accountancy bodies and professionals and small business owners, also criticised the pilot scheme and project implementation as “narrow” and “rushed”, and called on HMRC to develop guidance on digital exemptions “as a matter of urgency”.

The call for a delay was backed by several leading professional bodies.

“If properly implemented, digitisation could lead to efficiencies for taxpayers, agents and tax authorities,” said Adrian Rudd, Chair of the CIOT/ATT Digitalisation and Agent Strategy Working Group. “But many businesses will really struggle to get ready in time, and we support the committee’s recommendation of a delay for MTD for VAT.”

Impact assessment

The Lords also questioned HMRC’s impact assessment on the costs to businesses of MTD for VAT, stating that it will be far more than the government anticipates. A range of reasons was given for this, including the cost of upgrading older software systems or acquiring new ‘MTD compliant’ tools, and additional accountancy or consultation fees.

Although many witnesses supported digital record-keeping in principle, the committee saw no justification for HMRC to impose digital record-keeping on businesses, where exactly the same information would be provided as the current system.

Commenting on the report Simon McVicker, Director of Policy at freelance body IPSE, stated that a “surprisingly large” number of small businesses still keep paper records.

“They don’t have access to in-house accounting and finance departments like bigger businesses and are therefore at greater risk of being disrupted by the new reporting requirements,” said McVicker, whose body came out in support of the delay.

Key recommendations

Other findings and recommendations from the committee’s report included:

  • HMRC must publish how its communication and support systems will meet the needs of taxpayers and agents across different levels of digital capability and skills.
  • We regret that a small number of organisations have been given a six-month deferral, but not the smaller businesses who have the fewest resources to devote to implementation.
  • So far, no free software products have been offered by the software industry. The smallest businesses will struggle unless HMRC provides a basic free software option.
  • The government should publish its plan for the long-term development of MTD, including milestones and when key decisions will be made.
  • The penalties regime could be fairer and encourage taxpayers to remedy defaults promptly by giving taxpayers a longer grace period before penalties for late payment are applied.
  • The government’s claim that MTD for VAT will increase the amount of tax collected remains unconvincing. They should revisit their assumptions and publish another revised impact assessment.
  • Neither Treasury nor HMRC are taking the risks to implementation of Making Tax Digital seriously enough.

Missed the mark

While many of the Lords' assertions back up longstanding concerns expressed by AccountingWEB readers, institutes and other accounting professionals, several points made in the report did not ring true.

The committee’s assertion that no free option has emerged from the software industry (paragraph 57) is not correct. Several organisations, including Avalara, have made their products available at no cost.

The report also stated that a market in bridging software “does not seem to have emerged” (paragraph 59). According to AccountingWEB’s research (and HMRC’s list), a number of products are available, with more slated to arrive before April. A more accurate complaint could be that the products have been slow to market, partially due to the shifting timelines associated with the MTD project.

The Lords also implied that the reason for a six-month MTD deferral for a number of organisations with more complex requirements was due to their size, and favoured big business over small. As pointed out in AccountingWEB and other publications, the deferral was not based on size of business as implied, but according to sources close to the project was due to HMRC’s system not being ready in time.

HMRC has stated that it will consider its response to the Lords' report and respond in due course. A second report on HMRC powers and safeguards will be published in December.

About Tom Herbert

Tom is editor at AccountingWEB, responsible for all editorial content on the site. If you have a story that might interest us or wish to comment on the site's coverage get in touch via the site's private message function or Twitter DM (@AWebTom)

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to GHarr497688
22nd Nov 2018 20:10

If only HMRC people would read a post like this. How can the 6th largest - 5th before we did Brexit - economy in the world have a tax service which is run by clueless numpties?

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to GHarr497688
23rd Nov 2018 08:55

Thank you. One of the best posts on here. Period.

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to GHarr497688
23rd Nov 2018 12:08

I wanted to thank this seven hundred times but the software wouldn't let me or I'm too senile to use it properly.

I only have a few clients in the same boat, but why should they be coerced by the state into doing something they cannot comprehend?

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22nd Nov 2018 19:31

HMRC has still not written to me yet. When are they going to tell me that I need some kind of new electronic record in addition to my perfect paper records?

Their direction to their massive list of expensive cloud providers is very unhelpful - that is all they would direct me to even when I tweeted to them.

We need a list of 2 or 3 PC based non cloud bridging software providers, ideally free of charge ones or why can't HMRC make the software avilable free and then fulloy indemnify us for all loss and waste of our time if it does not work and for any security breaches arising from it.

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By Tornado
to EnglishRose
23rd Nov 2018 00:13

I got a letter.

It made a fabulous paper plane.

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to EnglishRose
23rd Nov 2018 09:03

HMRC will not write to me yet as I am in partnership on flat rate VAT. I understand Rebecca Beningworth has been asked for comments on Twitter. It would be informative and interesting to hear from her.

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22nd Nov 2018 23:07

Postponing MTD is not the answer.

Yes its a mess, badly rolled out and the IT behind it will be poor.

But it either needs to go ahead or be scrapped.

How people are supposed to plan and run their business and support clients with all this and the Brexit fall out.

I am cloud fan, but for other reasons like business development rather than MTD compliance.

HMRC need to make this happen next year or drop it, unless they are prepared to pay for my time preparing clients to hit targets that HMRC doesn't deliver on.

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to Glennzy
22nd Nov 2018 23:13

would u not feel that mandation could wait so that more time to get ready is possible for the smallest entities and especially now everyone is being written too

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to GHarr497688
23rd Nov 2018 09:09

Its already been moved 3 times, the extra time is not been used to take action, people just take the extra time to do nothing.

MTD in its current form is a minor issue at worst to deal with. Giving people time just means they take the further time to do nothing.

The smallest entities you refer are not involved.

Why rely on HMRC to advise our clients when that is what we get paid to do.

The fact that bridging software is allowed will give the further time needed for those not ready.

There needs to be a line drawn for people to work to, if it just keeps moving there is no point.

HMRC need to commit to this and deliver on it or drop it totally,

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to Glennzy
23rd Nov 2018 09:45

I just feel that HMRC and HMG have gone about this completely wrong. The whole idea of mandation and forcing every business to go digital was always a pipedream worthy of cloud cuckoo land. If some people want to stay with paper records and/or spreadsheets why shouldn't they? Those who want to go to the cloud where it suits them, fine, go ahead.

I've said before that HMRC should have learnt from what happened when they introduced mandatory electronic filing of PAYE returns. There should have been some way of incentivising people to go digital over a longer period (a tax credit was paid for 5 years to encourage early takers if I remember for PAYE).

The whole mandation bit is what stinks to me and MTD in its current format is nothing more than a penalty farming exercise for HMRC.

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to Peter Cane
23rd Nov 2018 10:10

Digitalisation of tax records is happening all over the world.

I was told in Spain your daily sales totals have to be reported every evening (but I think this is fact news)

In Poland every company has to submit that full nominal ledger, sales ledger, purchase ledger, fixed asset register and stock ledger every quarter!

However do I totally agree with you, I expect the HMRC are budgeting to increase their penalties income because of MTD.

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to david.bransbury
23rd Nov 2018 11:50

All perfectly true. Standard Audit File for Tax (SAF-T) is the global standard that is being interpreted by each country, and in it's pure form would bring blushes (and quicken the pulse) of UK businesses.

MTD is UK's own watered down version.

Also, see 'near live' invoice reporting for indirect tax in Greece and Italy starting in Jan 2019... and that does really impact businesses of all sizes.

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to rsergeant
23rd Nov 2018 12:16

rsergeant wrote:

Also, see 'near live' invoice reporting for indirect tax in Greece and Italy starting in Jan 2019... and that does really impact businesses of all sizes.


Be interesting to see compliance rates amongst small businesses.
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to Glennzy
23rd Nov 2018 09:56

Glennzy wrote:

MTD in its current form is a minor issue at worst to deal with. Giving people time just means they take the further time to do nothing.

Minor issue ? Well, that depends on the client's abilities.

I don't want to come along at the end of the year and find that the client has declared dividends on the basis of much improved profits, only to find that he's posted his year's PAYE payments to an asset account.

No, most will need nursing through it. Some, no doubt, will want me to do it all for them. And there'll be a cost to that which they didn't have before. There'll be a cost in terms of management time, too. Time they could've spent earning money. Overall, it'll be a lot more than HMRC's half a crown a week or whatever it was.

It's an issue. It's not minor.

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to lionofludesch
23rd Nov 2018 10:56

MTD in its current form is for filing VAT.

At the minute it has to filed via the government gateway, so at worst you have to then file it via bridging software so no big deal surely.

Valid point re dividends but they wont be an issue for some time.

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to Glennzy
23rd Nov 2018 12:12

I have heard that the government software for VAT will disappear

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to Glennzy
24th Nov 2018 15:02

Some clients wont sign up to a voluntary system, true, but many enabled clients will. The system will be tested with taxpayers that, essentially, know what they are doing. It will also give us time to know whats happening and be prepared - I dont think I can even open an agent account yet. Its crazy.

Then it can be rolled out later to others. Some will be better prepared by then. Some wont of course but HMRC will have had longer to correspond and run workshops for taxpayers with no agent. Agents will have had time to talk to clients about the full software available and even used bridging software in practice.

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to Glennzy
23rd Nov 2018 07:01

There is no reason why MTD requires using cloud accounting. It works perfectly well with spreadsheets.

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to johnhemming
23rd Nov 2018 08:51

johnhemming wrote:

There is no reason why MTD requires using cloud accounting. It works perfectly well with spreadsheets.

For now.

But for how long ?

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to lionofludesch
23rd Nov 2018 09:10

My guess is that when MTD for CT comes in you will have to report the quarterly dividends per shareholders along with their UTR and/or their NI number. (This has to happen otherwise there will be a big gap in the "death of the tax return" plan)

I think the next step for MTD for VAT would be reporting outputs and inputs by VAT rates.

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to lionofludesch
23rd Nov 2018 09:20

The concept is one of avoiding retyping of data. This can be achieved by various programming languages. There is no reason, for example, that you could not have a mainframe computer doing accounts which then links to the API. Actually spreadsheets are to some extent programming languages. I cannot myself see a real reason why people would ever be prevented from using spreadsheet computer programs. I only charge £20 per annum for the interface into MTD (once people move out of the free period) and some people can do it for free even then if they qualify.

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to johnhemming
23rd Nov 2018 09:14

Read my post properly, my clients are on cloud software for other reasons, MTD does not even come top 5 of reasons to have decent systems in place.

If MTD ever happens though they will be ready without any issue.

MTD will not work perfectly well with spreadsheets, there is a 12 month reprieve via bridging software which is all the delay people should need.

Also how do you know how good it will work with spreadsheets and bridging software.

As its a sticking plaster solution not a permanent one.

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to Glennzy
23rd Nov 2018 09:22

>MTD will not work perfectly well with spreadsheets
MTD does work perfectly well with spreadsheets. I am doing submissions with businesses as part of the pilot schemes and we are doing all of the digital links in accordance with the Vat Notice 700/22 we even do FRS submissions which some cloud providers cannot do.

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to johnhemming
23rd Nov 2018 09:33

Next April is only the first step on the staircase.

MTD will be ramped up, maybe on an annual basis.

What you can do in November 2018 might not be possible in November 2020.

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to lionofludesch
23rd Nov 2018 09:46

Exactly Lion, thats why delaying is not the answer, people just waste the time giving by extensions to do nothing.

If we are ready as a profession, HMRC need to step up and deliver on it.

As there are only digital tax systems available around the world I don't why they have not adopted one of them instead of trying to build our own with the terrible record HMRC have with IT systems.

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to Glennzy
23rd Nov 2018 10:02

Glennzy wrote:

Exactly Lion, thats why delaying is not the answer, people just waste the time giving by extensions to do nothing.

I agree up to a point.

But it'd be nice if HMRC were ready to sign us up on the Agent portal. Which they're not, as far as I know.

HMRC need to get their side up and running and only then give businesses a deadline for starting on MTD.

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to lionofludesch
23rd Nov 2018 09:49

It is obviously a process that is changing. Self Assessment, for example, involves doing quarterly figures rather than annual figures. I know the MTD documentation inside out because I actually write the programs myself that interface to the API.

However, I see no reason why a database that is managed in a spreadsheet will be unable to fulfil the requirements of the HMRC apis for tax returns. The customs situation is different and I think Estates and Trust registration really needs a database that is different to the default spreadsheet (although both could be done in Excel or Open Office, but I would not myself recommend it as it needs more of a relational database). Those would not have to run on the cloud, but it may be more cost effective - particularly for smaller businesses.

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to johnhemming
23rd Nov 2018 09:43

What is the point of putting time and resource into old technology that is only giving you a further 12 months before you have to bite the bullet and take positive action with a permanent solution.

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to Glennzy
23rd Nov 2018 09:50

Glennzy wrote:

What is the point of putting time and resource into old technology that is only giving you a further 12 months before you have to bite the bullet and take positive action with a permanent solution.


Where is your evidence for this claim? There is no reason that I can see for anyone using spreadsheets to do other than using a bridging provider. Some cloud users may have to use bridging providers for FRS or partial exemption anyway.
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to johnhemming
23rd Nov 2018 10:07

Well, again, more evidence suggesting that it is HMRC which is not ready for MTD.

I would also point you to the hundreds of exclusions which we have to deal with on Self Assessment. Most of them easily solved. What's the point in having digital tax if it doesn't get the right answer and you end up having to submit it old school on paper ?

Ironically, one of the things HMRC keep banging on about is "error prevention".

Hasn't worked too well with Self Assessment, has it ?

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to lionofludesch
23rd Nov 2018 10:14

lionofludesch wrote:

Hasn't worked too well with Self Assessment, has it ?


The Self Assessment pilot scheme for MTD is only partially live and is not scheduled for mandation before VAT. VAT is in front of Self Assessment and whereas you could use any experience with VAT as a guide to Self Assessment, you cannot use experience with Self Assessment as a guide to VAT. It is in my view entirely reasonable during a pilot scheme to bring in APIs gradually rather than all in one big rush. VAT actually only has 5 APIs and only one of those involves submitting anything (the VAT return).
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to johnhemming
23rd Nov 2018 10:20

I'm speaking of the current SA software, much simpler than MTD, but which HMRC still get wrong in over 100 ways.

I'm speaking of HMRC's poor software record generally.

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to johnhemming
23rd Nov 2018 10:24

Because bridging software is only a 12 months fix it is not a complete fix.

You will have to change to something else after 12 months, as MTD roll outs to other taxes the spreadsheet option wont work.

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to Glennzy
23rd Nov 2018 10:51

Glennzy wrote:

You will have to change to something else after 12 months,


Not for VAT. There is no reason to change after 12 months. I have put in completely compliant (including TFA and anti-fraud headers - points that people have missed) systems in the past months.

Glennzy wrote:

as MTD roll outs to other taxes the spreadsheet option wont work.

I accept that this is more complex. I am writing code (and have applied for production credentials from HMRC) which do a spreadsheet bridge for Self-Assessment.

This is a lot more complex. Having a schedule of dividends, for example, that then produces a total which gets submitted via the API is easily possible via a simple spreadsheet.

Doing full scale accounting for a self-employed business is more complex. It starts moving into a situation where a more structured accounting program might be better, but it is possible to do it with a spreadsheet.

When it comes to corporation tax the same issues apply. Obviously it is entirely possible, for example, for a business to do their own VAT return and to get their accountants to assist with the corporation tax return.

Capital Gains Taxes (and I have not seen any hints of APIs for these) are potentially a different order of complexity. I wrote some code for CGT (used by some of the larger stockbrokers) about 20 years ago and that was horribly complicated. It would, however, have been possible to start with a list of securities transations in a spreadsheet although capital receipts and sales of rights could be quite complex.

However, where ever SA and CT go it remains possible to do the VAT from a spreadsheet. Hence it is a permanent solution in as much as anything is a permanent solution.

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23rd Nov 2018 10:08

Great article Tom
Its just what I want to read...another year deferred...keep going.

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23rd Nov 2018 10:24

If MTD is poorly implemented, that means a potential loss of VAT revenue to HMRC, the consequences of which would be felt very quickly! All that in the same year as Brexit. Genius!

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to kevin503
23rd Nov 2018 10:35

Could be a gain.

Who knows ?

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23rd Nov 2018 10:40

Tom, re 'Missed the Mark' - at the time the HOL were considering evidence there was no bridging software available. I know because I was one of the 8 practitioners who had a round table meeting with the subcommittee. I'd signed up for bridging software (Absolute, BTC etc) before the HOL meeting and received emails saying they'll get in touch when the software was available. I'd also attempted to sign up with Avalara from your AW article but all I got was a page on Avalara's website saying it was 'not found'. I printed it and took it to the HOL meeting with me. But Avalara is not MTD software, it is merely bridging software. It is MTD software that the HOL are talking about. HMRC has said there would be free MTD software (not bridging software because HMRC was talking about fee MTD software before HMRC agreed to accept bridging software). When HMRC held its original consultations the free software was not required to deal with VAT which implied there wouldn't be any that could deal with VAT. Tom, please publish a list of free software (not bridging software).

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23rd Nov 2018 10:47

Duplicate because the first post reported a sift server error

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23rd Nov 2018 10:50

Why doesn't HMRC put all the resources it is currently spending on MTDV into processing timeously and efficiently the data it does currently receive?
I have just been advised by HMRC that the 2 paper Self-Assessment returns for 2017-18 which I sent by pigeon (albeit signed-for first class pigeons) on 19 October will be processed by 31 December. It took 2 weeks before I could get confirmation that the Returns had actually been received (I did get PODs with a scrawled signature from Royal Mail tracking system but didn't trust them and my clients HMRC records online still showed the Returns as outstanding).

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to leahjane
30th Nov 2018 12:01

What's a "POD"?

I find this "Post" difficult to read as it contains so many (undefined) initial letters. They are NOT shortcuts. They merely add to confusion in the reader's mind, which, in turn, has to re-interpret what was conveyed. That process SLOWS DOWN the reading. Please use WORDS.

The Good-English Professor (is back)

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23rd Nov 2018 11:11

I have read and inwardly digitaligested all the posts and my conclusion is as I have always thought, there is no place for MTD.
HMRC have a perfectly adequate system of investigation if they want to see all business transactions (the actual source documents).
So my conclusion is quite simple. HMRC should allow us Accountants to deal with all the admin and just concentrate on investigations and collection (where agent strategy should have been by now).

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23rd Nov 2018 11:12

As a respondent to the enquiry, again this year, I have naturally closely followed this masquerade.

If you haven't watched the eponymous fool, Middleton and Ruth Stanier, another dumb civil servant giving their "answers", then please do so:

https://parliamentlive.tv/Event/Index/99ca5180-ad74-4833-bb81-fdc8612f53ed

Thereafter, one MUST realise the core problems.

Unless one is a Snake Oil Salesman for Cloud services, of course.......

The transcript is here:

http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidence...

For me., Lord Lee of Trafford summed it all up rather nicely:

Q. 48. "Lord Lee of Trafford:

The firm impression that we have at the moment is that we are heading for a giant car crash. ".

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to Michael C Feltham
23rd Nov 2018 20:07

Thanks for the link. The Lords made some very good points throughout.
HMRC indicatd they may help with showing tax payers which software to use. that would be very ehlpful if they could have a list saying the following is software "for a PC and which does not use the cloud and is bridging software" - those would be the 3 things I would be looking for and ideally no fee or if there to be a fee then one I pay once only forever.

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23rd Nov 2018 12:11

Very interesting, personally I hope it is deferred. In the meantime I will check out Avalara

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to Vallery Lee
23rd Nov 2018 12:45

Alvera is a name I've never heard of and when they refer to free its for bridging and not accounting , why when MTD is filing for all Taxes eventually is all this work being done for VAT. VAT records on excel will not produce the four set of accounts needed through the year. Am I thick ? The only way to get MTD to work is for ALL Tax payers to keep accounts prepared by an Accountants four times a year . I just can't understand what the hell is going on .

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By trecar
23rd Nov 2018 12:20

I am currently studying change management as part of my post graduate degree. Looking at the introduction of MTD from that point of view I would be inclined to mark it as -5 on a scale of 1 to 5 where 5 was excellent. The HoL is correct in their assessment of the situation. Whether MTD is desirable or not is beside the point. This is about whether HMRC will be successful in implementing it or not. So far the indications are that they will not. To introduce it at a time of intense uncertainty, as is existing over Brexit is total madness. About time the government grew up and understood their role in behaving responsibly by postponing the introduction to a more favourable time. They should also consider quality as a function of their decision making process.

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By Tornado
to trecar
23rd Nov 2018 12:43

'About time the government grew up and understood their role in behaving responsibly by postponing the introduction to a more favourable time'

They will, they have no choice.

They may take it up to the wire though, as they have nothing to lose by doing this.

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to trecar
23rd Nov 2018 18:15

As part of your studies, just wondering if you could research when was the last time HMRC considered quality to be a priority in any part of the administration of the tax system and in particular in relation to their customer care and service.?

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to trecar
23rd Nov 2018 20:09

It is also quite rare they bring something out for those of us who are the least rich smallest one person businesses (those of us who have to charge VAT). The video (HMRC) implies we are big boys using software already and using accountants because we reach the giddy heights of £85, 000 a year turnover whereas in fact we are the very busiest companies with fewest resources and plenty of us don't use or have an accountant and have paper records that are very accurate.

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