Holding HMRC to account: ICAS assesses HMRC’s performance against the Charter standards
By Susan Cattell, Head of Tax Technical Policy
31 May 2021
Susan Cattell outlines the ICAS assessment of HMRC's performance against the Charter standards over the last year, for the Charter Stakeholder group.
What is the HMRC Charter?
HMRC is also required to make an annual report reviewing the extent to which it has demonstrated the standards of behaviour and values included in the Charter.
The Charter Stakeholder group
The group is made up of representatives of the tax community, including ICAS, ICAEW and the CIOT. It holds regular meetings with HMRC to discuss how the Charter is being reflected in taxpayer and agent experience of dealing with HMRC. It also gives formal input about how HMRC is performing against the standards in the Charter, for inclusion in the annual report.
ICAS assessment of HMRC performance 2021
ICAS recently submitted its assessment of HMRC performance against the Charter standards for April 2020 to March 2021 to the Charter Stakeholder group.
Our overall assessment noted that this has been a challenging year for HMRC, agents and many taxpayers. There has been some positive engagement between HMRC and the professional bodies, particularly in the discussions on the introduction and operation of CJRS and SEISS. We hope this can be built upon in future.
We recognised the enormous efforts made by HMRC to get the COVID support schemes up and running in a tight timeframe – and in getting payments to businesses and individuals quickly. However, HMRC had to move staff to work on the Covid support schemes (taking them away from other work) and like other organisations has had difficulties with staff absences etc. The result for taxpayers has been that various customer service targets linked to dealing with post, answering calls, issuing UTRs, processing returns/VAT registrations etc have been missed.
Agents are also experiencing severe ongoing problems contacting HMRC due to problems with the Agent Dedicated Line (ADL). It would be helpful for HMRC to be open and transparent about backlogs, their recovery plans and when something like normal service might be resumed.
Overall, ICAS would like to see:
- more recognition of the importance of the role of agents in HMRC systems and practice;
- more transparency about problems with HMRC services (and plans to get them back on track);
- urgent action to ensure that all taxpayers and agents can access the right HMRC expertise; and
- action to address some of the problems highlighted last year (particularly agent access to HMRC systems and agent authorisation) which remain significant issues.
Feedback on specific service standards
In our feedback on some of the key standards in the Charter, we highlighted some important issues reported to us by Members and noted some successful work by HMRC around compliance checks.
Significant points covered were:
Recognising that someone can represent you
There remains a significant gap between this Charter standard and HMRC’s actual performance. There has been no real improvement since last year. The main issues:
- Agents still cannot see and do what their clients can see and do, in spite of HMRC’s commitment to achieving this.
- Agents were completely excluded from the SEISS system on the grounds that it would have taken too long to build a system with agent access. However, if the default position for HMRC systems involved agent access this would cease to be an issue as the basic architecture would exist. Agents were also excluded from the enhanced TTP process.
- HMRC’s position still seems to be to build a system with taxpayer access – and only consider agent access as an afterthought. Agents then do not get access at all, or their access is less than optimal. The basic architecture for all systems should incorporate agent access.
- Agents still cannot access information in clients’ Personal Tax Accounts – it is vital that this is addressed when PTAs (and BTAs) are replaced by the single digital account.
- The digital handshake process for authorising an agent for TRS and the 30-day CGT reporting system continues to cause significant problems for agents and clients. It is disappointing that HMRC has not taken any steps to improve the process.
Getting things right
- Poor quality and lack of consistency in HMRC responses on VAT issues.
- Poor quality responses on direct tax issues provided by HMRC helplines and in correspondence – and a lack of consistency between call handlers. Issues which in the past would have been resolved by one exchange of letters now take at least two.
- HMRC series of YouTube videos to help taxpayers understand the compliance check process. HMRC proactively sought input from stakeholders in developing these and they give clear, concise information.
Making things easy
- The digital handshakes used to authorise agents for TRS and 30-day CGT reporting are cumbersome and not accessible or easy to use. In spite of the issues being raised repeatedly with HMRC no improvements/changes have been made.
- Improved HMRC help and support page to explain the compliance check process and improved compliance check letters.
- Issues with the CGT reporting service causing confusion and problems for taxpayers and agents.
Being responsive
- Positive feedback on HMRC’s work on CJRS and SEISS, including help to businesses with the initial implementation of CJRS.
- Ongoing problems for most agents and taxpayers (those without Customer Compliance Managers) to access the right HMRC expertise to deal with technical issues (or practical issues with HMRC systems). Escalation processes from helplines are not working properly. These issues predate the pandemic and need to be addressed as a priority.
- Deterioration in the service for companies with Customer Compliance Managers.
- Agents experiencing long delays getting through to HMRC to resolve issues which cannot be resolved by other means.
- Long delays to various routine but essential processes, including processing 64-8s, issue of UTRs and dealing with VAT registrations.
Difficulties encountered by agents and businesses arising from VAT policy team initiatives.
Tell us about your experiences of dealing with HMRC
The Charter Stakeholder group will be continuing to meet with HMRC regularly. We need ongoing feedback from Members about your experiences of dealing with HMRC and how HMRC is performing against the Charter standards.
Please send us your input by emailing tax@icas.com.