ACCA welcomes the opportunity to respond to the HMRC call for evidence on Raising standards in the tax advice market: strengthening the regulatory framework and improving registration
Given the limitations of the existing partial regulatory framework and the impact it can have on the standard of the market as there is no holistic approach, the government has concluded there is a need to strengthen the regulatory framework to meet the aim of raising standards in the tax advice market.
- ACCA believes that trust, transparency, and certainty lie at the heart of a healthy relationship between a tax authority, the taxpayers and the agents who interact with it. A lack of investment in HMRCs staff and digital capabilities has, over time, damaged relationships between HMRC, compliant taxpayers, and the professional agents supporting them, with service standards at HMRC falling to an unacceptably low standard.
- Enhanced education for members of the general public is crucial to ensure people understand tax, regardless of whether they choose to file taxes independently or with support from an adviser.
- ACCA believes that a focus on improving HMRC’s capacity to deliver taxpayer and professional agent service and effectiveness to give us the modern, efficient tax system we need, would not only support the delivery of these objectives, but ultimately improve public sector finances and boost productivity in the UK as a whole.
- With the professional body approach, HMRC could minimise the drain on its own time and resource. As a professional body ACCA has a range of existing requirements and standards which members must adhere to, those holding a practicing certificate must be fit and proper, will have completed a range of examinations, and adopted ACCA, International Federation of Accountants (IFAC) and Professional Conduct in Relation to Taxation (PCRT) requirements and standards.
- ACCA members are subject to robust levels of regulation and standards enforced by ACCA’s rulebook2 as well as licensing, monitoring, investigations, and disciplinary functions. All of which operate alongside the requirement for members in public practice to deliver high levels of quality assurance and protection for taxpayers. This holistic oversight of a professional body for all its members provides the insight to support effective regulation and protection.
- ACCA always favours a risk-based approach in monitoring related elements and draws on its knowledge of its members and sector to underpin this. We believe this would also be appropriate for government because it targets the areas government are concerned about. While there would be additional cost and time commitment requirements from professional bodies, ACCA believes that these are justifiable given the potential benefits.
- ACCA believes that all professions should be included in this requirement as it adds significant value and integrity within the system for all that deal with clients for tax services.
- We agree that a transition period gives the market sufficient time to adapt the introduction of mandatory professional body membership, however, we would welcome the introduction for specific areas such as R&D to be brought forward separately in a shorter period.
- One of the areas of future developments which we feel must be accounted for in implementing mandatory professional body membership is the way in which different taxes may change over time, and therefore, the way in which the provision of tax advice may evolve.
To read the response in full, please download the consultation response document found on this page.
