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Tools for HMR&C?
Having just received this morning 3 simple repayment claims calculations from HMR&C which are are incorrect I wonder whether we should help the Revenue by sending them toolkits? I even sent in my own calculations of the refunds and schedules of income.
We will have to see, Rebecca.
We will have to see Rebecca.
Any sane adviser (or taxpayer) would wish to know what HMRc regards as risk areas, and what HMRC is looking for. To that extent, any disclosure and transparency is of course welcome. It should benefit all (including HMRC) which represents a win - win for all parties.
But of course the objective of the toolkits is to push folk into accepting HMRC's view of things as well as make them aware of them. It's a possibly fine line, but not really (given the comments made before they came out, and the examples thus far). It is not a cynics view, it is an analysis of their statements and views espoused though policy pronouncements and WT groups. (And of course your reference to insurance only underlines the very point ; toe the line or else.)
To the extent that taxpayers and advisers wish to accept HMRC view, that's fine.
It's true that in an ideal world, all parties would know, simply and uncontroversially, where exactly they stand in tax law for every single detail. But even with the best endeavours of all concerned, that ideal world is a long way off. Do the toolkits bring that day nearer?
If the toolkits develop "merely" as "layman's versions" of statute, case law and HMRC interpretation thereof, they may be neutral or benign. I just am a bit cynical that it would be like this, but let's see.
But let's be clear on their objective, else we will succumb (yet again) to spin. HMRC wishes to use the toolkits to establish what they want done, not necessarily what the Government (sorry, I should say Parliament, but that increasingly becomes a stamp) or the Courts want done. To the extent that coincides with tax payer's interests (by clarification of HMRC approach) that's fine. We'll see what else it is used for before we get carried away with how useful they are.
My money would be on it being another step along the line of "we only want you to pay the right amount of tax". Yep, that's good. Er, well, with some important caveats to say the least!!
They are designed to be a boon to HMRC. Fair enough (my earlier comment was meant literally). To the extent that they transparently and more simply clarify what HMRC already state (though their increasingly comnvoluted manuals) as their views, they can be useful to a practitioner, small or large.
Toolkits
When I worked for one of the Big 6 we had these except they were called 'aide-memoires'. Each question had to be signed off by the preparer to show that it had been considered and by the reviewer. I think all of the Big 6 used them. They became part of the review process and eventually became a costly paper exercise in many cases. They were not without merit for prepares if they were targeted. It was when they decided to produce one for every aspect of return and computation preparation that they became an administrative chore.
Toolkits
Rebecca Benneyworth’s sneak preview of the HMRC toolkit provides a valuable insight into HMRC’s strategies on tax risk analysis. At CCH Fee Protection we hope that the toolkit will in fact give the professionals and their clients an increased advantage in filing a correct and accurate return. It’s still early days to know what effect it will have but we see it as a positive step towards mitigating risk for accountants and their clients.
Rebecca commented that it would be interesting to see whether fee protection insurers request details of which toolkits a practice uses before setting premiums.The premium for fee protection, as in any kind of insurance, would of course be affected by the perceived level of risk of a claim. CCH Fee Protection would need to look at any factors that may affect the frequency and cost of claims. John Bower,Managing Director, CCH Fee Protection, a Wolters Kluwer business