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An important deadline
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MTD ITSA: A question of capacity

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Making Tax Digital for income tax self-assessment is going to lead to a significant increase in work. Paul Aplin raises alarm over the capacity issue this will create in accountancy firms.

9th Aug 2022
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Over recent months more detail has emerged about the mechanics of MTD ITSA: how the quarterly reports will align, the complexity that basis period reform will add for many businesses and the reporting detail set out in the recent HMRC notices.

As the MTD ITSA pilot expands, we will gain even more insight into just how different things will be at a practical level from April 2024.

Many firms will be reflecting on how they may need to adapt their business models to cope with the new regime.

The way we work now

I spent 40 years in practice, mainly advising small and very small businesses. Some clients used accounting software, some used spreadsheets and some kept manual records. I saw good and bad records, irrespective of the record keeping medium. Over the last few years, because of the general trend towards digital and with impetus from MTD for VAT and Covid 19, more and more businesses have made the transition to accounting software. It has been evolution rather than revolution, but MTD ITSA will trigger a quantum shift, with over four million self-employed and landlords affected.

Currently, information is imported into the agent’s software either by keying in from manual records or digitally (by mapping directly from the client’s software or spreadsheets). The agent makes the necessary adjustments for the final accounts and tax return. This is generally a once-a-year exercise unless the agent does the VAT returns.

For a small, VAT registered sole trader with some property income the reporting obligation amounts to four VAT returns plus the self-assessment return – five in total. 

How it will change

From April 2024, the same taxpayer will be required to file four MTD VAT returns, four MTD ITSA quarterly returns on the self-employment income, four MTD ITSA quarterly returns on the property income, two End of Period Statements (one each for the self-employment and property income) and a Final Declaration – 15 in total. Even at the most superficial level that is a very significant increase in work.

The question is who will do it?

Simply based on the number of reporting events, having the capacity to move from the current to the new regime will be challenging, but there is more to it than that.

Capacity and responsibility

We now know that the MTD ITSA quarterly returns will be linked to the tax year rather than the accounts year. Where the client looks to their agent to deal with the quarterly returns, that linkage will make it even harder to spread the increased workload, because the peaks will be around the same quarters for every client in MTD ITSA – the months of July, October, January and April will be virtually unavoidable pressure points.

Some firms will look to flexible working to cope with the peaks. Others will look to bookkeepers to help spread the load.

MTD ITSA will, I believe, provide a significant opportunity for bookkeepers to take on a central role, dealing with the quarterly reporting as well as maintaining the core digital records. If I’m right, that will raise new issues.

For a start, bookkeepers will need authorisation to deal with the quarterly filings and to view the relevant information on HMRC’s systems. The question of multi-agent authorisation under MTD ITSA is under active discussion with HMRC, but time is short. With only twenty months to go until the big bang in April 2024, this is an urgent issue.

While pressure on capacity will provide some of the incentive to share the additional workload between agents and bookkeepers, some will also be down to the difficulty of making a profit – or even recovering – on the increased work at normal charge-out rates.

There will be practical issues to consider, such as the digital handover from bookkeeper (or client if they do the quarterly reporting) to agent.

  • Where will responsibility rest for the accuracy of the quarterly returns and EOPS?
  • How easy will it be to make corrections and adjustments for the final accounts and tax?
  • Will engagement terms need to be revised?
  • Who will be responsible for avoiding late filing penalties (given the fact that each new filing obligation will create a new potential trigger for penalty points or charges)?

Advice and support

It isn’t, of course, just about the mechanics of the new reporting requirements. Someone has to advise those adopting accounting software for the first time on the choice of software and apps. Someone has to oversee installation and set-up. Someone has to train the client if they intend to keep the records themselves. Someone has to provide ongoing support.

Again, I suspect many firms will struggle to do this as the staff who are best at it (knowledgeable about software and with good teaching skills) will be in high demand.

And where will this activity sit within a firm? Will it be with the tax team (as MTD ITSA is fundamentally a tax compliance matter), the accounts team (getting from the core business records to a set of accounts being their province), or – if the firm has one – the business support team?

Whatever the answer, care will be needed to ensure that the focus is not just on MTD compliance but on helping clients get something useful for running their business from the software and apps. 

Again, I see potential for an enhanced role for bookkeepers here.

The future

Things will undoubtedly be very different, not just in terms of the mechanics of MTD ITSA, but in the way it will change what we do and who does it.

Capacity – especially in the run up to April 2024 and the transition – is going to be a problem, but I believe that good bookkeepers will be well placed to provide a significant part of the solution.

The role bookkeeping will play in MTD ITSA with the subject of a recent AccountingWEB ‘MTD Bootcamp’ webinar. You can catch up with this episode on demand now.

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Replies (57)

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By ireallyshouldknowthisbut
09th Aug 2022 15:21

I wouldn't worry too much myself. Whole thing is a a complete joke and is nowhere close to being launched.

HMRC have completely over-extended themselves trying to dictate how bookkeeping is done. Just as they did with the failed business record checks.

HMRC's job is to collect taxes. MTS ITSA does not help with collecting taxes, it actively hinders it. Quite frankly we are looking at people in positions of influence to get off the fence and start having some very frank discussions with HMRC and get this farce ditched rather than facilitating what is going to be the biggest red tape burden for small business in living memory, set to land smack in the middle of a major recession.

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By Hugo Fair
09th Aug 2022 15:22

All good points ... and I note the careful attempt to avoid leaving too many direct questions hanging in the air (through frequent reference to 'issues' that remain as unasked questions)!

But the sad fact is that whilst you, Paul, may be asking questions to which it appears that HMRC can only respond 'No comment' like a guilty-looking cove in any of the crime dramas out there ... HMRC don't seem to have even asked the questions (of themselves or their 'partners').

Without the basic Q&As (aka detailed spec) of the files/processes/validations/amendments & submissions that supposedly constitute MTD ITSA ... the chances of reliable software are slim and the likelihood of effective support is negligible. So the relevance of data ownership & collection, plus the relationship between taxpayer/bookkeeper/accountant, remain in a fluid state for now.

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Replying to Hugo Fair:
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By Jo Nokes
09th Aug 2022 20:14

That last summary of what is missing is what I have been puzzling over . Assuming the trader or landlord can be organised enough to file some data, each quarter, how do we as accountants get hold of it, turn it into a proper set of accounts, and file the end result to HMRC? And retain a digital trail? Is this really possible?

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Replying to Jo Nokes:
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By Hugo Fair
09th Aug 2022 21:58

As my chief developer 'explained' to me (through gritted teeth) many moons ago ... "*Anything* is *possible*. Which aspect did you have in mind - accurate? / reliable? / robust? / intelligible to users? / affordable? / using fewer than 24 hours in a day?"

I never asked him that question again - but was careful to tease out the different feasibility factors. And we got on fine for over 25 years - producing (unlike HMRC) software to a plan, rather than just a plan (aka 'hope') for software!

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Replying to Hugo Fair:
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By NotAnAccountant2
10th Aug 2022 12:20

Hugo Fair wrote:

As my chief developer 'explained' to me (through gritted teeth) many moons ago ... "*Anything* is *possible*. Which aspect did you have in mind

One of the important benefits agile is supposed to bring to the table is that questions get asked *AND ANSWERED* early, minimizing risk of major requirement changes due to only discovering issues and problems towards the end of a project.

But HMRCs implementation of agile has totally failed in that goal while still gaining all of the disadvantages of agile.

The ICAEW thing raised with HMRC (and reported here recently) was really good (from my PoV as a developer rather than an accountant)

It asked the questions that the MTD system architects and developers need to answer and in a way that doesn't assume much accountancy knowledge at all The only obviously accounting terminology I noticed was related to cash vs accruals. Any person working on MTD for HMRC who doesn't know what an agent is needs to be sacked!

A competent software developer who doesn't know what cash vs accruals means (and many won't because it's not something most will encounter) will be able to find out enough about it in any of the first few hits on google to then ask intelligent questions of people who do understand to fully comprehend the (somewhat subtle to a non-accountant) issues it causes with MTD.

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Replying to Jo Nokes:
By ireallyshouldknowthisbut
10th Aug 2022 12:55

Jo Nokes wrote:

That last summary of what is missing is what I have been puzzling over . Assuming the trader or landlord can be organised enough to file some data, each quarter, how do we as accountants get hold of it, turn it into a proper set of accounts, and file the end result to HMRC? And retain a digital trail? Is this really possible?

It depends which iteration of the project you look at. This project is so "agile" its like Lizz Truss policy announcement. 24 hours later they change their minds.

In some versions the junk data Q reports are totally ignored and your just file the year end as now.

However think HMRC then realised this pretty much admits the whole project is 100% pointless (and clings onto the highly important tax estimate) , so I think they then changed the spec so you file the difference between junk Q reports and the answer. The data will appear by magic in your tax software. So we are told. Just like the current P60 data, P11D and all the rest of it we were promised reliably appears on the 6th April. Of course it does. Actually I think they originally said all the dividends and savings would appear too along with student loan data, NI info the whole works, but that seems to be a long forgotten old project, just like iXBRL which was also going to change the world. But didn't, just made it harder to file.

Its amazing how much money they can throw at bad IT.

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By JustAnotherUser
09th Aug 2022 15:26

Are some of you still assuming this is happening?

I think the memo to cancel got left under a party plate smeared with pizza at one of the none-covid parties they've been having.

Good read and summary.

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Tornado
By Tornado
09th Aug 2022 15:52

It looks as though you have searched back at the numerous threads on AWEB over the last few years about MTD and summarised most of the the points already raised, discussed and not yet resolved.

Look in particular for threads on the preparation and submission of POINTLESS quarterly returns that many will find impossible to deal with as they will not have the resources, funds or additional time to allocate to this.

Perhaps the Professional Bodies could recognise this and do something about it as whilst this Accountant will not be trying to do the impossible, many will try and find themselves in deep trouble and may seriously require assistance from their Professional Bodies.

Thanks (13)
Replying to Tornado:
Richard Sergeant
By Richard Sergeant
10th Aug 2022 10:17

Bravo Tornado for the very judicious use of bold text. Carefully deployed, it can be a lethal weapon.

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By Paul Crowley
09th Aug 2022 16:24

The just are not enough good bookkeepers to fill the void
I really dislike clients asking me to suggest a bookkeeper
The good ones have all the work they need

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Replying to Paul Crowley:
Tornado
By Tornado
09th Aug 2022 17:55

As you say, knowledgeable and reliable book-keepers are hard to find and any assumption that there will be anywhere near enough to service an additional million or so people in MTD for ITSA, is naive to say the least.

We should have stopped looking for solutions to the problems a long time ago and spent more time trying to eliminate the cause of the problems.

We also need to remember that it is NOT the responsibility of Accountants to make MTD work, it is the sole responsibility of HMRC and it is they that need to take action, not us. We can get involved when HMRC present us with a system that is up and running and fully tested that we can just plug into.

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Replying to Tornado:
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By bendybod
10th Aug 2022 09:37

Can't we just meet HMRC with their own response to any communication with them: we are looking at around 4 months' time to respond to that query.

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By Jo Nokes
09th Aug 2022 17:16

Pau, you set out very well the enormous increase in the reporting burden, especially the compression of the work into just four months, but blithely assume bookkeepers will appear to take up the slack. Don't you think with 18 months to go, you should be supplying answers. And if you can't do that, don't you think you should be telling HMRC that their dream is impossible. Frankly, you appear to be part of the problem, along with the software houses and AWeb, pushing seminars and boot camps, as if they have all the answers when we know that they don't. I'm really fed up with this. Clearly the PBs have let us down

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Replying to Jo Nokes:
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By Open all hours
09th Aug 2022 21:59

An excellent post. Thank you.
I too have read enough and endured enough smug webinars.
Notice how the Q&A in the webinars was shortened and in the last one it was timed out altogether. Can’t think why! Surely the software has ALL the answers, (except that it hasn’t). Put things to them straight and they (Freeagent in particular) call it ‘abuse’. Abuse is what they are seeking to do to my clients. Time to draw a line under this sorry episode. As Tornado says, when HMRC have it sorted maybe we’ll plug into it.

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Replying to Jo Nokes:
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By spilly
09th Aug 2022 23:22

I can foresee a great reluctance by clients to pay us sufficiently for these multiple quarterly submissions. And also an unwillingness to pay us to do any initial guidance and training if they want to have a bash at it themselves. So the first year or so will just be submissions of rubbish.

Thanks (5)
Replying to spilly:
Tornado
By Tornado
10th Aug 2022 09:05

'So the first year or so will just be submissions of rubbish.'

What will change after the first year?

With each rubbish Quarterly Return submitted, the accumulative errors will add to to the rubbish heap and make it 100 times more difficult to sort out. It seems better to limit our exposure to only as much as we can handle, and avoid the possibility of being blamed for not submitting returns on time with the expectation that we will pay the late filing penalties for clients, perhaps running into thousands of pounds.

These are the realities of the MTD Project.

I do hope the Professional Bodies have Benevolent Funds that are well topped-up.

Thanks (6)
Replying to Tornado:
boxfile
By spilly
10th Aug 2022 20:40

I’m assuming that after a while HMRC will quietly drop the need for small landlords to use it, and that maybe the threshold for all tax-payers will also be raised considerably.

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Replying to spilly:
the sea otter
By memyself-eye
10th Aug 2022 10:55

Rubbish?
Not just in the first year.

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Replying to Jo Nokes:
By ireallyshouldknowthisbut
10th Aug 2022 08:48

I am rarely able to find a good bookkeeper when I need one for a client. Any good ones I am in contact with get busy very quickly and are then are not taking on new clients.

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Replying to ireallyshouldknowthisbut:
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By bendybod
10th Aug 2022 09:39

The industry as a whole is facing a huge shortage of staff or subcontractors. Just try to recruit anyone at any level anymore! Fewer people to do more work. Yeah, that'll work.

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Replying to Jo Nokes:
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By Red1960
10th Aug 2022 15:03

Couldn't agree more with almost all that you have said.

If the PBs were responsive to their members they would have launched a public awareness campaign to inform people of the dangers that MTD presents and supporting a campaign for the entirety of these ill concieved and ill thought out proposals to be abandoned.

They did not do this for reasons that we all know which bring shame and disrepute to all concerned.

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By North East Accountant
09th Aug 2022 18:10

Supply and demand will mean that capacity will eventually sort itself out but the first few quarters will be a massive shake up as the 06/04/24 meteor strikes.

Prices will rise (lots more work to do) and many self-employed/landlords just won't pay the price needed to get the job done properly.

If firms don't want to expand (many) client numbers will have to reduce to those willing to pay for the increased service needed to do it right.

Who is going to help the unrepresented? Will HMRC have the capacity? ........no chance.

The unrepresented will struggle to get help leaving them to have a bash themselves, pay some cheap shark who'll file any old rubbish or drop out of the tax system officially and carry on regardless. Will HMRC have the capacity to deal with this?.......no chance.

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By GHarr497688
09th Aug 2022 19:38

As you will all know I am an avid commentator on MTD ITSA. I have over 40 years experience within an Accountancy practise having worked in and now owning a small firm. I deal with small clients on a daily basis. The theory of Sage back 40 years ago was the same now as it was then. You enter your data - you produce your figures and they are filed to HMRC. The only difference between now and MTD is that the Accountant intervenes and reconciles the clients data to that which HMRC receive to calculate the tax. The client will either try and produce their own records or use a book-keeper or the Accountant. The records might be a combination of manual or computer or just prime records. Most clients and book-keepers understand very little about tax and what is required. As the work is time consuming book-keepers are paid very low rates and in my experience often are just keen amateurs. If the Accountant does the book-keeping this is the best option however it's either a loss leader for the Accountant or very expensive for the client. In all my years working book-keepers are like gold dust is they are any good. I have seen many book-keepers ruin a clients records and then just walk out or get the records in such a mess they can't be corrected so the Accountant has to go back to basics. The Accountants job is awful being the middle man between Accountant and Tax man. Often the Tax man will blame the Accountant for their mistakes. MTD can't work if standards are to be maintained as it's too time consuming , not enough Accountants or book-keepers a lack of client interests in time scales and too much dependance on the Accountant taking over the function - Fees also will not be possible to charge. Whilst computers change , sadly human nature does not. HMRC are expecting the impossible . If HMRC make is a law and force the change then standards of records will do down the pan and "rubbish" will be filed just to meet the deadline. I am 100% confident that this is already happening with MTDVAT and HMRC can't be bothered to check. Obviously no one will know any different as HMRC will outsource surveys designed to hail this as a success even when it's on it's knees. HMRC have to justify the costs of this project which is now running 9 years late and still there are more questions than answers.

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By Ammie
10th Aug 2022 10:02

Short capacity may not be a bad thing.

Look at BP they're just loving life!

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Morph
By kevinringer
10th Aug 2022 10:10

The short answer is we accountants do not have the capacity to digitise our clients records, nor to correct the digital records prepared by our clients (which can take longer than scrapping our client's attempts and starting again from scratch). Our job is to prepare accounts and Tax Returns, it is not to teach our clients how to use a computer or how to become bookkeepers. We all know it takes years of experience to become a bookkeeper, so how can we teach our entire client base? Add to this the huge number of experienced accountants that are retiring by 2024 because of MTD (I know several personally) will increase the shortage of accountants further.

The only way we could cope with the workload is to (1) switch to monthly bookkeeping for all clients and (2) hire staff now to get them trained up. But if we hire staff now, who is going to pay for them? Given the massive financial pressures on clients as a result of Brexit/Covid/Inflation/Energy costs, clients can't afford the extra costs. And in any case, HMRC have kicked the MTD-can down the road so many times and the complete lack of detail and disastrous pilot (only 8 participants after 5 years), I can't see how MTD can go live in 2024. So who is going to risk training more staff when they might not be needed in 2024?

And what is the point of MTD? We warned HMRC it would increase error and sure enough, the VAT gap increased the first year of MTD VAT. All that cost for less tax. Maybe the increase in the tax gap is the "saving" that HMRC said "customers" would benefit from as a result of MTD? Silly me, I had thought HMRC had been arguing the cost of the software and time was the saving. No, it's because everyone will be paying less tax because the software allows them to put all their personal expenses against the business and claim VAT on everything including wages, drawings and the VAT payment itself. HMRC don't seem to mind at all and accept any rubbish as long as it is digital rubbish.

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Replying to kevinringer:
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By leekris
10th Aug 2022 11:03

I suspect that there will be some clients who will not want to pay me to do quarterly returns but will submit the returns themselves assuming suitable software is free or cheap. The any old rubbish gets submitted four times a year (personal expenses etc.) and they think "that's easy I might as well do the annual submission myself". "Hey my tax bill is a lot lower than it used to be and I don't have to pay an accountant either."

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Replying to leekris:
Morph
By kevinringer
10th Aug 2022 11:21

And the tax gap will become a tax chasm. We've warned HMRC but they have had their digital blinkers on since 2015 and see and hear nothing we say.

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By jon_griffey
10th Aug 2022 10:28

Although the pressure points will be July, October, January and April. It is significantly worse than that as the workload will be skewed heavily towards the filing date.

You will not get the info on day 1 after quarter end. Clients need time to do their books and very many will always leave it until the last minute. This means that the bulk of the quarterly work will be compressed into a week or so.

I don't care how well trained your clients are or how slick the software is. It will be physically impossible to give the data even a cursory look, let alone do the bookkeeping yourself, correct mispostings, deal with bank feed issues etc and still need to find time to do all your other work. That is without any staff sickness, Christmas breaks etc.

Hopefully a new PM and Chancellor will put an end to this madness.

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Replying to jon_griffey:
Morph
By kevinringer
10th Aug 2022 10:54

jon_griffey wrote:

You will not get the info on day 1 after quarter end. Clients need time to do their books and very many will always leave it until the last minute. This means that the bulk of the quarterly work will be compressed into a week or so.

That's why I reckon it would have to be done monthly. There'll be additional admin chasing records monthly, and chasing aggressively to get them in quickly. And we all know that picking up a job 12x a year is more time consuming than 1x a year.

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Replying to jon_griffey:
Morph
By kevinringer
10th Aug 2022 10:58

jon_griffey wrote:

That is without any staff sickness, Christmas breaks etc.


Also, Easter is in April for 2025 (Q4 of 2024-25). In fact it is in April for 80% of the years so that's even more time lost. And don't forget that unlike VAT, we don't have the extra 7 days for MTD ITSA.
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Replying to kevinringer:
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By bluebaron
10th Aug 2022 15:52

And as for July, that's summer holiday time here!

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By Homeworker
10th Aug 2022 10:40

Please don't forget that in the first year we will also be trying to prepare the accounts and tax returns for the previous year too, so (more than) double the workload.

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the sea otter
By memyself-eye
10th Aug 2022 10:59

I'm so,so, glad I quit when I did.

As an aside good bookkeepers will up their prices - my wife charges £50/hr now.

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Replying to memyself-eye:
Morph
By kevinringer
10th Aug 2022 11:20

Wow, that's more than we charge. Maybe we should give up being accountants and become bookkeepers instead for a small number of clients. It would be a lot less hassle.

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Replying to kevinringer:
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By Paul Crowley
10th Aug 2022 15:16

I had considered that too
Loads of accountants
Zero reliable bookkeepers
Why waste my time with all the risk

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Replying to Paul Crowley:
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By Hugo Fair
10th Aug 2022 15:25

But then your clients would be accountants (who probably know less about accounts than you do) ... not a recipe for a quiet stress-free life!

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Replying to Hugo Fair:
Morph
By kevinringer
10th Aug 2022 16:04

But if the clients are submitting direct to HMRC, that's HMRC's problem not mine.

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By dmmarler
10th Aug 2022 12:17

Even if there are more trained bookkeepers to do the work , all this electronic activity requires more electricity, more cloud space, and so on, besides the upgraded kit, software etc., we will all need. We, the government/HMRC should be considering global warming at this point. Perhaps this is argument we should use against this nonsense, particularly in the middle of a heatwave.

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By adjadj
10th Aug 2022 15:45

"The months of July, October, January and April will be virtually unavoidable pressure points."

We need to consider the other factors that occur in these four months.
- July is the month of school holidays and experience tells us people are not always focussed on work matters.
- October is half term time - many people take short breaks at this time
- January - the hellish month when every man and his dog submits tax returns at the last moment
- April - often a time of the Easter break and a busy time for accountants as they produce company reports based on accounting years ending in late March or early April.

As mentioned by others the MTD work will be focussed towards the end of the 30 day period.

We need to get the conversation going to extend the 30 day reporting to 45/50 days so smoothing the workflow to something that seems a bit more feasible

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Replying to adjadj:
Tornado
By Tornado
10th Aug 2022 15:49

'We need to get the conversation going to extend the 30 day reporting to 45/50 days so smoothing the workflow to something that seems a bit more feasible'

What we really need to do is eliminate the need to submit pointless Returns in the first place. Tackle the problem and not the consequences.

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Replying to Tornado:
Morph
By kevinringer
10th Aug 2022 15:59

Correct, I'm all for digitisation of transactions for commercial reasons, but digitisation for the sake of digitisation is pointless as is the submission of numerous additional returns.

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Replying to adjadj:
boxfile
By spilly
10th Aug 2022 20:52

All our bookkeepers are part-time, most with children at school. They usually cut down or stop work during the school holidays, meaning that we will be running with low staffing levels at precisely the time that all this unnecessary quarterly reporting should be happening.
And that’s before we get on to how clients are just not going to have stuff ready in time unless they are VAT-registered and more used to prepping information on a regular basis.

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By bluebaron
10th Aug 2022 15:59

It's always been the quarterly submissions bit that has horrified me. I still think MTDfIT will go ahead in some form in 2024 (maybe the £10K threshold will be raised, soft landing for penalties perhaps), although it will be a complete disaster, especially with many taxpayers only finding out about their obligations in February/March 2024 for an April 2024 launch! I also expect mass non-compliance.

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Tornado
By Tornado
10th Aug 2022 16:26

MTD ITSA: A QUESTION OF RESPONSIBILITY

Perhaps this is the real question here.

Who is responsible for making MTD for ITSA work, HMRC or us?

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Replying to Tornado:
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By Jo Nokes
10th Aug 2022 17:18

According to the software houses, it certainly isn't HMRC, it's clearly down to us to get our clients on board. Certain respected members of the profession appear to think that as well, nuch to my disappointment.

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Replying to Jo Nokes:
Morph
By kevinringer
11th Aug 2022 10:08

If the software industry reckons it is our responsibility and not HMRC's, whose responsibility is it to get unrepresented taxpayers onboard?

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Replying to kevinringer:
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By Jo Nokes
11th Aug 2022 11:09

Clearly the software industry, as evidenced by all the adverts extolling their product

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Replying to kevinringer:
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By Carol Jefferis
11th Aug 2022 12:52

Clearly ultimately the responsibility of the taxpayer to meet requirements they had no knowledge of, just like the Capital Gains Tax on UK property returns that no one told them about.
I think we all need to write to our MPs (of whatever party) to put them on notice that there is a fast approaching fiasco which HMRC has utterly failed to warn taxpayers about and also write to Kier Starmer and Rachel Reeves to give them as much ammunition as possible to use against the government if they choose to do so.

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By Jo Nokes
10th Aug 2022 16:40

Wouldn't it be great if, just for once, a contributor came back and replied to the criticism of his or her piece. Here is Paul Aplin, suggesting that in effect, our problems will be solved by the appearance of bookkeepers in their thousands, to take up the challenge. Is this realistic or is it pie in the sky?
The comments to his article have raised really serious questions but there are no answers. I just checked on the ICAEW MTD for IT hub. It hasn't been updated since November 2021, I wonder why?

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Replying to Jo Nokes:
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By adjadj
10th Aug 2022 18:20

The hub may not have much information but ICAEW have been active. They recently highlighted key information gaps in this submission to HMRC https://www.icaew.com/-/media/corporate/files/technical/icaew-representa...

You can view the accompanying ICAEW comment here: https://www.icaew.com/insights/tax-news/2022/aug-2022/mtd-itsa-notices-a...

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