ACCA welcomes the opportunity to respond to HMRC’s Tax Administration Framework Review - new ways to tackle non-compliance. While broadly supporting the proposals as drafted, support is contingent upon addressing several key elements.
On 22 January 2025, ACCA responded to HMRC’s Tax Administration Framework Review - new ways to tackle non-compliance. It follows earlier comments on the Tax Administration Framework Review - enquiry and assessment powers, penalties, safeguards.
ACCA continues to emphasise how an effective tax system is built on its simplicity, certainty, and stability. ACCA agrees with the proposals as drafted – especially if they reduce delays, align disparate processes, and enhance dialogue between HMRC, professional agents and taxpayers. However, support is contingent upon addressing the following elements:
- Long-term investment key to implementation
The proposed powers highlight the need for long-term investment in HMRC. There is currently little confidence in HMRC service levels – to the point where 89% of ACCA accountants say they hinder their ability to support clients. According to the Association of Revenue and Customs (ARC), investment totalling £910m is needed to ensure HMRC is adequately resourced. ARC estimates that UK businesses are losing £1.1bn in time costs.
- Powers and procedures built with taxpayers in mind
If taxpayers select an agent to act on their behalf, then the agent should receive the same information. Therefore, ACCA highlights an opportunity to improve dialogue between HMRC and authorised agents. It can also bring about greater alignment with the relevant HMRC Charter standard.
- Further work on cost impacts
ACCA believes costs impact interactions, including with fee protection and professional indemnity insurance, require further investigation. We would be happy to help HMRC on this area of work.
- Established safeguards
ACCA believes eventual decisions (on any of the options) should rest on clearly understanding their application and scope. ACCA looks forward to work on actions (either individually or in combination) that addresses the risk of potential implementation creep. Equally important is analysis on when such actions might apply.
To read the response in full, please download the consultation document found on this page.
