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Where next for Making Tax Digital?

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With a challenging timeline and shrinking resources on which to deliver it, the government’s much-delayed Making Tax Digital project now stands on the brink. Tom Herbert weighs up the options ahead for the UK’s flagship digital tax transformation project.

20th Jul 2023
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After a six-month hiatus following the latest delay, we’ve suddenly seen a flurry of Making Tax Digital (MTD) activity, with the National Audit Office (NAO) and Public Accounts Committee (PAC) both investigating the programme, its aims and its performance thus far.

At points, MTD watchers could be forgiven for wondering if there were two projects with the same name, as HMRC officials pointed to a successful rollout of MTD for VAT and invigorated ‘co-creation’ sessions with accountants and vendors. 

Meanwhile, the NAO and PAC members offered a withering assessment of HMRC’s performance, while the tax and accounting professions shook their heads and bemoaned a lack of engagement and a failure to listen to feedback from stakeholders.

Now postponed five times and currently arriving eight years late, the project is slowly reaching a crunch point, where its future needs to be decided once and for all. 

So what are the options facing this current government, or indeed one that may come after it in 2025? Should they continue the rollout, change the specifications or jettison it altogether? And how will the profession react? 

Full steam ahead

According to the tax authority’s CEO Jim Harra, HMRC is confident it will deliver Making Tax Digital for income tax self assessment (MTD ITSA) to its new timelines.

Optimistic officials are talking up getting small businesses into the pilot scheme early, while yesterday a hand-picked selection of accountants and vendors took to social media to enthuse about attending one of HMRC’s new ‘co-creation sessions’.

However, when considering the deadline we quickly arrive at the digital elephant in the room – can HMRC actually deliver on this

To get a full cycle of testing for the ITSA part of the programme before mandation in April 2026, the pilot needs to be up and running with a decent number of participants signed up before the start of tax year 2024/25 – 6 April 2024 (and that’s without testing its new penalty system alongside the main trial).

This is around nine months away. With the pilot currently closed to new entrants, no timeline for reopening or removing any of the restrictions that dogged the previous attempts to make it work, widespread cynicism from the accountancy profession and a software industry muttering mutinously about a lack of engagement, this feels challenging. 

Delay again

Given that it’s been delayed five times already, what’s another postponement between friends? HMRC’s systems weren’t ready for previous deadlines and the project was pushed back, and the chaos that would be unleashed if the tax authority pushes ahead without everything in place doesn’t bear thinking about.

But an alternative viewpoint might be that delaying for a sixth time removes the last vestiges of credibility from an already diminished project, and heightens other risk factors including the current speed of technology change. In a submission to the PAC, AAT stated that postponement further exposes HMRC to the risk that “technology could outpace MTD, making the programme redundant”.

With the bold assertions coming from Whitehall, this additional kick of the can seems unlikely but not impossible.

Modify or cut quarterly reporting

In a recent letter to HMRC, ICAEW said that dropping quarterly reporting from MTD ITSA would “change the narrative” and also ease problems like multiple agents acting for a single taxpayer. The Institute’s Frank Haskew added that the “administrative burden associated with quarterly updates is disproportionate and needs a rethink”. 

The letter also questioned the need for quarterly reporting as part of the mechanics of MTD ITSA. “Quarterly updates provide HMRC with little or no assurance about the quality of the underlying digital records,” stated Haskew.

Instead, the accountancy body suggested sticking with the annual reporting cycle while introducing requirements to maintain digital records and submitting details of income from self-employment and property directly from software. 

While the decoupling of quarterly reporting from the MTD ITSA programme seems a pragmatic way for HMRC to win back a little trust from the profession, based on recent pronouncements from Whitehall it seems doubtful this option will get the green light. 

Jonathan Athow, HMRC’s director general of customer strategy and tax design, told the PAC that there were “no plans” to remove the quarterly reporting element of the programme, instead doubling down on the tax authority’s ultimate ambition to have real-time information that would update HMRC’s systems in the background - with CEO Jim Harra restating his belief that this will help close the tax gap.

Cut out the smallest businesses

The Treasury is currently conducting a ‘small business review’ to decide whether MTD  quarterly reporting is appropriate for people with income between £10,000 and £30,000, with a decision now expected when Parliament returns in September.

This cut-down version of MTD removes an estimated 2.6 million taxpayers from the process and answers critics of the programme who flag the increased reporting and cost burdens for the smallest businesses.

While this is possibly the most realistic of the climbdown options on the table, as one of the main reasons for introducing MTD is to improve small business record-keeping and cut the tax gap, it’s hard to see why HMRC would consider it. 

The move would also reduce the software options for taxpayers, as the total addressable market would be considerably cut. AccountingWEB understands there are at least three smaller vendors involved in the programme that would leave the market if such a decision was made, potentially leaving taxpayers with a handful of larger vendors to choose from.

Scrap MTD and achieve its goals through self assessment

Finally, we come to the billion-pound decision – will the government really push the big red button on MTD? 

The NAO’s figures state that up to March 2023, £642m had been spent on MTD ITSA, with a further £295m spent on the now-completed MTD for VAT project. 

It would be a bold move indeed for any government to be seen to torch more than half a billion pounds, but would it be foolhardy?

A forthright submission to the PAC from accounting firm Crundell & Co stated that HMRC’s plan to keep taxpayers below a certain threshold on the current self assessment system – essentially running two tax systems in parallel – was ‘crazy’.

“How will [having] two tax systems in place make the process easier?” stated the submission, adding that instead, it will add “unnecessary complication and admin”.

“The current self assessment system works well, it does not need to be replaced. If the ultimate aim for HMRC is quarterly tax payments, these could easily be brought in under the current self assessment system, our clients would actually welcome that move!”

ICAEW’s submission pointed to the high levels of online self assessment filing that have been achieved without mandation or forced change – approximately 96% of 12 million returns and rising. Instead, businesses had adopted digital record keeping in their own time and reported this as a benefit.

This points to a system that, while it has its issues, isn’t in need of full-scale replacement. Moreover, ICAEW points out that digital transformation needs to happen in parallel with the overall simplification of tax policy, an aim made harder with the abolition of the Office of Tax Simplification.

While sections of the tax and accountancy community would heartily toast a move to scrap the MTD project, the humiliation for HMRC’s senior leadership team would be total. 

While it's impossible to see this current government writing off its digital transformation project, it’s not beyond the realms of possibility that an incoming government might use its first budget in 2025 to do so. 

AccountingWEB has repeatedly asked our potential government-in-waiting what it makes of MTD, but perhaps understandably they’ve decided that ignoring this particular bear trap and hoping it goes away is the best policy.

Replies (49)

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By OrmeGoat
20th Jul 2023 09:42

Government projects which need scrapping:

1. HS2
2. MTD
3.

(To be continued)

Thanks (12)
Replying to OrmeGoat:
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By Open all hours
20th Jul 2023 15:02

Net Zero
Ulez
LTNs
20MPH zones.

Thanks (4)
Replying to OrmeGoat:
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By Hugo Fair
20th Jul 2023 15:39

But you need someone with the courage to wield an elephant gun.
[Sorry animal-lovers, but it was Tom that introduced elephants into the story!]

However, "the digital elephant in the room – can HMRC actually deliver on this?" understates the issue specifically in the way that you hint.

The difficulty is identifying this particular pachyderm within the herd of grey beasts marauding around Whitehall ... knowing that only wounding one of them would lead to carnage (even greater than what's happening right now).

A sacrificial lamb is needed to pull the trigger (odd image) ... at last a job for the Harra?

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Replying to OrmeGoat:
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By AndrewV12
27th Jul 2023 09:22

New NHS computer system.
Paying France 62.2 million to stop the Boats
Far to Easily writing off the Bounce back loans.
........

Over to you lot

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By TB93
20th Jul 2023 09:47

Where next? Hopefully the scrapheap.

With the introduction of the CGT MTD reporting and planned MTD ITSA quarterly reporting, it seems HMRC is steadily introducing more ways in which they can hit you with penalties and fines for missing the ever increasing reporting requirements.

I wonder what more they can look to fine us for..

Shame we can't invoice them for not answering our calls or responding to letters.

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Replying to TB93:
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By coates
20th Jul 2023 10:43

not forgetting all the wasted time trying to get clients ready for MTD ITSA for HMRC to postpone it - can that time be billed to them?

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By Yossarian
20th Jul 2023 09:52

Perhaps 'Making Tax Digital - The Musical' starring Harry Hill as Jim Harra?

Thanks (11)
Replying to Yossarian:
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By unclejoe
20th Jul 2023 10:00

Or a TV sitcom like we used to have in the good old days. They could call it Faulty Towers with John Cleese as JH.

Thanks (9)
Replying to unclejoe:
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By AdamJones82
20th Jul 2023 11:39

The episode with the sign "Flowery Tw@ts" certainly seems apt for Jim Harra et al

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Replying to unclejoe:
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By Yossarian
20th Jul 2023 13:09

unclejoe wrote:

Or a TV sitcom like we used to have in the good old days. They could call it Faulty Towers with John Cleese as JH.

Major: 'Making tax digital arrived yet, Fawlty?'
Fawlty: 'NOT YET! Sorry, not yet Major'

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By Ammie
20th Jul 2023 09:56

Never mind the implementation of MTD, who is going to be to hand to resolve the flood of queries and troubleshooting problems at a time when HMRC are culling staff levels and suspending telephone lines?

I would like to see how a bot handles the situation and it won't be Jim Harra, that's for sure.

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Replying to Ammie:
Pile of Stones
By Beach Accountancy
20th Jul 2023 17:34

If Jim Harra was a bot that would explain a lot.

No personality, no awareness of the outside world and an inability to answer questions...

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By SteveHa
20th Jul 2023 10:01

Quote:
But an alternative viewpoint might be that delaying for a sixth time removes the last vestiges of credibility from an already diminished project

I think that ship has already sailed.

Thanks (11)
Replying to SteveHa:
Morph
By kevinringer
20th Jul 2023 10:15

Agreed. All credibility has gone. It took HMRC 8 years to admit MTD ITSA was more complex than HMRC thought. It just shows how poor HMRC's understanding of their own tax regimes are. If it takes HMRC 8 years to recognise this, there's no way MTD ITSA will happen.

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Replying to kevinringer:
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By Southwestbeancounter
20th Jul 2023 13:58

kevinringer wrote:

there's no way MTD ITSA will happen.

Good!

That's exactly what should happen - it should be binned before it costs any more millions of wasted taxpayers money!

Thanks (1)
Replying to kevinringer:
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By djtax
21st Jul 2023 10:14

HMRC poor understanding of their own tax regimes may well be due to the fact that almost all of their senior management have little or no tax background. Long gone are the days when they were career tax inspectors with a wealth of personal knowledge and experience in tax matters.

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Replying to djtax:
Morph
By kevinringer
21st Jul 2023 10:36

You're spot on djtax. When I attended a MTD meeting with HMRC, all the HMRC presenters were IT people. None of them had any knowledge of tax, and no experience of small businesses or taxpayers.

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Replying to kevinringer:
RLI
By lionofludesch
22nd Jul 2023 16:37

kevinringer wrote:

Agreed. All credibility has gone. It took HMRC 8 years to admit MTD ITSA was more complex than HMRC thought.

Took me less than eight seconds.

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By sodge2000
20th Jul 2023 10:12

MTD for VAT has cost me money. I use Sage and to get that MTD compliant meant paying for a new version at over £600. I now have to use bridging software at £9 for each VAT submission. There was nothing wrong with the online filing for VAT as I am doing the same thing but with a another company in the middle.

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Replying to sodge2000:
By ireallyshouldknowthisbut
20th Jul 2023 18:14

Ouch, that is proper price gouging. I use xero and vt. No extra charges.

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Replying to sodge2000:
Morph
By kevinringer
21st Jul 2023 09:41

Sage has really milked MTD VAT to the maximum. Prior to MTD, I had clients using what was called Sage Instant at the time. This included a module to file the VAT straight from the software. This was pre-MTD VAT. The clients would input transactions, I would input what they'd omitted, reconcile the bank etc and file the VAT. Clients could buy a perpetual licence of this version of Sage for a one-off £90-£100. Clients generally would use the same software for about 5 years before upgrading. Therefore the cost of the software was about £18-£20 a year.

When MTD VAT started, Sage decided to cash in by making Sage subscription only, and only supplying the MTD VAT module in the subscription software. At the time Sage were charging about £15 a month. Annual cost £180. That's a 10x increase just for the MTD VAT module. From a user's perspective, the MTD VAT module worked similarly to the pre-MTD VAT filing module. There's no way the actual cost to Sage of building that MTD VAT module was 10x the whole of the remainder of the software. So this was clearly Sage taking advantage of MTD VAT.

A client recently signed up to the latest version of Sage Instant (Sage 50cloud) and is being charged £72 a month. That is £864 a year. That is 45x the cost pre-MTD VAT. Sage is definitely exploiting their customers. Those customers do have the choice of moving to cheaper alternatives, but there are costs with moving.

I'm sure there are many Sage users who wish they had stuck with the pre-MTD VAT software and used bridging software instead of upgrading to saves own MTD VAT software. But there is no route to downgrade back to pre-MTD VAT versions of Sage, so they're stuck with higher costs or change software.

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Morph
By kevinringer
20th Jul 2023 10:13

"At points, MTD watchers could be forgiven for wondering if there were two projects with the same name, as HMRC officials pointed to a successful rollout of MTD for VAT...."

HMRC inhabit a parallel universe to the rest of civilisation. Just look at HMRC's unilateral decision to close the Helpline for 3 months. The Treasury Committee were very critical of this. Did HMRC take this on board? No. Instead, HMRC have announced a 30% permanent reduction in helpline staff. HMRC inhabits an alternate reality where everyone is digitally competent whilst HMRC think it is ok to continue with manual worklist and 1960s computer batch technology.

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Replying to kevinringer:
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By sodge2000
20th Jul 2023 10:20

I am not sure that a reduction of "helpline staff" will make much difference. I am yet to find any helpline staff helpful.

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Replying to kevinringer:
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By Hugo Fair
20th Jul 2023 15:47

HMRC do NOT "inhabit a parallel universe to the rest of civilisation" ... or at least in their eyes that would be considerably underselling their aspirations.

They believe in the multiverse ... and their central tenet is that whatever they think or say IS true in a majority of those universes (at some point in the past or future)!

We are merely an annoying background noise on one of the anomalous outlier universes.

Thanks (5)
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By biff1001
20th Jul 2023 10:34

Yes MTD for vat is such a success that it now takes months for clients to actually get a vat number after application!

Meanwhile we accountants look incompetent in front of our clients!

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By agknight
20th Jul 2023 10:40

The humiliation of HMRCs leadership team needs to be total.

Thanks (10)
Replying to agknight:
Morph
By kevinringer
20th Jul 2023 11:00

They are immune to it, because they inhabit a different reality.

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By timmylea
20th Jul 2023 10:43

Back when MTD was introduced, HMRC made a distinction. They referred to MTDfB, which was MTD for Business.

They quickly dropped this (or just forgot it). In fact, one of the first MTD deliverables was the personal income tax accounts for individuals, so HMRC immediately went in a non-business direction.

But I think HMRC need to be reminded that MTD was supposed to be about business compliance. Asking grandma and granddad to use MTD ITSA to report their pension isn't doing anybody any favours. On the other hand, it's not unreasonable to expect a freelancer, or trade, or somebody running a side hustle, to keep their accounting digitally. After all, they're running a business.

Asking larger businesses liable for corporation tax to use MTD seems reasonable, too. In other words, the MTD requirement load should always be commensurate with business size.

This is why MTD for VAT worked, even though there were teething troubles. The first wave was only for those over the VAT threshold. And while it now applies to all VAT businesses, you could argue that anybody registering for VAT does so because they've reached a certain business size where they need to start taking VAT seriously.

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Replying to timmylea:
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By Moo
20th Jul 2023 11:50

'Asking grandma and granddad to use MTD ITSA to report their pension isn't doing anybody any favours. '
Don't be so judgemental about grandparents, I'm a grandma and fairly tech savvy whereas the 30ish plumber that I'm trying to get to do some work for me can't even cope with email. Lord knows how he does his accounting, probably with one of those magical accounting apps on his phone that hugely overpromises in terms of accuracy.
And anyway MTD for pension incomes is still a long way over the horizon (as in not needed, never going to happen), the MTD challenge for grandma and granddad was generally going to be the rental income from family owned properties often shared with several different generations and that is an issue for all ages.

Thanks (2)
Replying to Moo:
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By NotAnAccountant2
20th Jul 2023 12:33

Moo wrote:

And anyway MTD for pension incomes is still a long way over the horizon (as in not needed, never going to happen), the MTD challenge for grandma and granddad was generally going to be the rental income from family owned properties often shared with several different generations and that is an issue for all ages.

Hmmm, you are aware that HMRCs dream is that people in MTD submit *everything* via MTD. This hasn't changed:

https://developer.service.hmrc.gov.uk/guides/income-tax-mtd-end-to-end-s...

Quote:

Final declaration brings together all the data that a customer needs to provide to HMRC to reach their final tax liability for a specific year. Using this process allows the customer to finalise their tax position for any one tax year, taking into account all sources of chargeable income and gains, whether business income or otherwise.

It is also the process by which most formal claims for reliefs and allowances and any deductions will be made, where these were previously included within a Self Assessment tax return.

Customers are able to tell us at this point (subject to the existing limits) how they wish any losses available to them to be treated.

Customers can make a final declaration from 6 April Year 1. The deadline for final declaration is 31 January Year 2. The software should remind customers to help them to meet this deadline.

We suggest that you retrieve the self-assessment metadata first to check there are no validation errors.

If there are errors the calculation will not have been generated. To view the error messages, call the retrieve self assessment tax calculation endpoint.

The customer must go back and amend the digital records. The software should resubmit the revised summary totals for the relevant periods, then call the intent to crystallise endpoint again.

So anyone with property income in MTD will, eventually, have to worry about pensions, pension contributions, charitable giving, bank interest, etc, etc, etc.

Thanks (1)
Replying to NotAnAccountant2:
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By Moo
20th Jul 2023 14:16

'all the data that a customer needs to provide to HMRC to reach their final tax liability for a specific year. '
And that is rather the point where pensions are concerned, the 'customer' does not need to provide information on pensions (at least UK ones) because HMRC already have this information - either direct from DWP or where private and occupational pensions are concerned through the PAYE system. You say you are not an accountant and that is all too apparent as any tax practitioner using tax return software will be aware that the data prepop function actually works pretty well for pensions paid through PAYE and the state pension figure can generally be picked up from the agent gateway account.
I assume from your defensive stance that you are from HMRC or from the software industry and like Mr Harra you are clinging on to a pipe dream that has eaten up so much time and money to date.

Thanks (1)
Replying to Moo:
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By Geoff56
20th Jul 2023 13:03

"Lord knows how he does his accounting"

Perhaps with a handwritten cash book, which might work well for him? Or perhaps he just hands it all over to his accountant, which could work equally well.

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Replying to Geoff56:
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By Moo
20th Jul 2023 14:21

I agree he may well hand everything over to his accountant but even then the accountant will likely get pretty fed up with a client who doesn't respond to emails despite showing an email address on his website. Maybe accounts and tax returns can be sent for approval via WhatsApp but I've never heard of it happening so they are presumably communicating by Royal Mail.

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Replying to Moo:
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By Geoff56
20th Jul 2023 14:31

Yes, I have a few clients who have e-mail addresses but never look at them! I've worked out who they are. They just like it all done by post, which is fine by me.

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Replying to Geoff56:
Morph
By kevinringer
21st Jul 2023 09:21

Same here. I know my clients well enough to know who reads their emails and who does not. If they want it on paper, they can have it on paper. I provide the service they want. I charge for the service they want.

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By Finacta
20th Jul 2023 10:46

If there was a Delete button for HMRC, I would press it.

I was told last week by an agent that their systems wouldn't allow them to search by the VRS reference number they provided in order to track a VAT registration. That's the level we're at in terms of digital competency.

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Replying to Finacta:
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By biff1001
20th Jul 2023 10:53

I think all the competent IT guys at HMRC left when they started going hard on IR35 in the public sector.
Both HMRC and Companies House systems have been a nightmare since!

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By rmillaree
20th Jul 2023 10:51

"According to the tax authority’s CEO Jim Harra, HMRC is confident it will deliver Making Tax Digital for income tax self assessment (MTD ITSA) to its new timelines."

OMG is this guy Delusional ? or does he not care as he will be gone from his job before he is taken to task for his misplaced (again) overconfidence.

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By ireallyshouldknowthisbut
20th Jul 2023 10:51

This is what a large failed IT project looks like in its death throes.

Some stakeholders desperately holding on to a fantasy, whilst everyone else has moved on some time ago.

We are past denial, we are past anger, this is now bargaining in terms of trying to carry on with half a project (ie without quarterly reporting, or for some tax payers and not others). Depression is yet to set in with HMRC, but we will be through to acceptance. Eventually. To be fair some players are still in the denial stage at a senior level at HMRC, but given a year to respond to post is normal, then they might not have got the memo yet.

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Replying to ireallyshouldknowthisbut:
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By NotAnAccountant2
20th Jul 2023 12:24

ireallyshouldknowthisbut wrote:

This is what a large failed IT project looks like in its death throes.

I've quoted this before but it's worth restating.

https://en.wikiquote.org/wiki/C._A._R._Hoare

They're all good but:

Quote:

There are two ways of constructing a software design: One way is to make it so simple that there are *obviously* no deficiencies, and the other way is to make it so complicated that there are no *obvious* deficiencies. The first method is far more difficult.

(HMRC hasn't yet made it to the second, there are still obvious deficiencies)

Quote:

[About PL/I] At first I hoped that such a technically unsound project would collapse but I soon realized it was doomed to success. Almost anything in software can be implemented, sold, and even used given enough determination. There is nothing a mere scientist can say that will stand against the flood of a hundred million dollars. But there is one quality that cannot be purchased in this way — and that is reliability. The price of reliability is the pursuit of the utmost simplicity. It is a price which the very rich find most hard to pay.
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By AdamJones82
20th Jul 2023 11:41

If the definition of MTD for VAT being a success is that I now submit the same set of 9 numbers under a different system, then so be it. Money REALLY well spent (insert rolling eyes emoji)

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Replying to AdamJones82:
By ireallyshouldknowthisbut
20th Jul 2023 12:51

Agreed, one online filing system replaced by another one, which is more expensive to the end user as you have to pay for software which HMRC previously offered for free.

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By swimmer
20th Jul 2023 16:29

https://www.change.org/p/scrap-quarterly-reporting-mtd

Please sign up to the new petition to scrap quarterly reporting (MTD) by clicking on the link above.

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By moneymanager
20th Jul 2023 18:16

I can remember walking in to my local tax office, unannounced, meeting face to face in minutes and completing my business directly with a case handler, here's a novel idea, let's bin "digital" and go back to analogue.

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By Marlinman
20th Jul 2023 18:52

Scrap it and sack those responsible for its implementation.

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By Marlinman
20th Jul 2023 19:04

Scrap it and sack those responsible for wasting taxpayers money.

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By GHarr497688
20th Jul 2023 19:06

MTDITSA Instruction guide:
Keep your books as you have always kept them as it suites your business needs.
Take the books and then input them onto a system that HMRC says you must use or be fined.
Makes hundreds of mistakes putting them on a Computer system you don't understand.
File meaningless figures to HMRC each quarter and receive a misleading unchecked tax bill that will mislead you.
Send all the rubbish to the Accountant to look over who wont be able to understand anything you have produced.
Scrap all the work you have completed.
Ignore all the irrelevant estimated tax liabilities
Refile your Accounts as you have always done for Self Assessment
Get the Accountant to work out the complete mess the new system has made.
Pay the larger bills to your Accountant and Software Provider.
Go to the Doctor and say you feel totally depressed.

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RLI
By lionofludesch
22nd Jul 2023 16:38

Anybody remember John the Plumber and his free app?

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By AndrewV12
27th Jul 2023 09:18

'Now postponed five times and currently arriving eight years late, the project is slowly reaching a crunch point, where its future needs to be decided once and for all. '

Trust me they are not going to turn back now, they have passed the point of no return (The NAO’s figures state that up to March 2023, £642m had been spent on MTD ITSA, with a further £295m spent on the now-completed MTD for VAT project. )

I hate MTD

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