Appointment by digital handshake: what will your clients make of HMRC’s digital authorisation of agents?
Implicit in the concept of digital tax, is the need for an effective digital means of appointing a tax agent. While it would technically be possible for authorisation via a firm’s existing software, HMRC is expecting your clients to login via Government Gateway and have their identity verified in order to confirm your appointment.
Philip McNeill asks ‘What does this mean for you and your client?’.
ICAS Briefing paper
Discussions are ongoing and ICAS has prepared a briefing paper setting out possible objectives, concerns and practical challenges.
HMRC has not made a final decision on the future, but piecemeal fixes are being introduced as new tax services are created on the HMRC Enterprise Tax Management Platform (ETMP).
This means that the way clients appoint tax agents is different depending on the service on offer. For example, 30-day CGT reporting, MTD for VAT or the Trust Registration Service. This situation is unlikely to be resolved until all taxpayer information is moved from HMRC legacy systems on to ETMP.
What do clients expect from you? Are your client’s willing and able to interact with HMRC online? Do they consider that they have delegated all digital and non-digital contact with HMRC to you?
Will it require additional non-chargeable time to help clients navigate Government Gateway and confirm your appointment? Will some clients be unable to comply?
As HMRC is acting as gatekeeper to any non-digital options, it will be HMRC’s assessment of your client’s digital capability which will bar non-digital options.
The aim must be to design a system which addresses the needs of all parties as far as is practicable. Resources are not infinite, but the system should:
- enable all taxpayers to appoint a tax agent in a manner which best suits their personal needs and aspirations. This must embrace both choice and disability. Taxpayers should not be forced to jump through digital hoops in order to achieve their desired objective
- be secure. There need to be adequate safeguards to protect taxpayers, agents and HMRC from criminal use of the system
- facilitate compliance. It should be a ‘want to use’ system which encourages successful taxpayer interaction
The final shape of the system will impact all agents in practice and all client taxpayers.