ACCA welcomes the opportunity to respond to HMRC’s consultation on Improving the data HMRC collects from its customers.
At the heart of these proposals lies the fundamental question: what is the role of HMRC? As noted in our response to HMRC’s consultation on Digitalising Business Rates, HMRC has a long-established role as assessor and collector of taxation, payments and customs in the United Kingdom, but its primary role is not that of a data collection body. HMRC data is shared under specific instances of legislation with other Government bodies and certain public sector entities to facilitate their activities, but it is used to supplement, rather than replace or outrank, the data held by those bodies. We advise HMRC to put these plans on hold, pending a comprehensive assessment of the data collected under the Making Tax Digital (MTD) programme.
We are concerned that the proposals have neither been costed, nor do they outline key processes that would be critical to programme success. As noted in our letter to the Chancellor of the Exchequer in September 2022, HMRC is insufficiently resourced to fulfil its business-as-usual obligations at present; as it is currently resourced, we do not believe that HMRC can perform the functions of a tax collection agency, play a role in the benefits system, and act as a government data hub.
To read the response in full, please downloadn the consultation document found on this page.