Comments from ACCA to HM Revenue and Customs on Draft legislation: The Value Added Tax (Amendment) Regulations 2018.
ACCA has engaged with HM Treasury and HMRC from an early stage on the Making Tax Digital proposals and we have expressed throughout significant concerns that notwithstanding the potential benefits, the transition to digital record keeping and quarterly reporting, and potentially payment, of taxes will create difficulties for many sectors, transactions and tax rules if not introduced in a suitably considered fashion.
ACCA firmly believes in the value of digital tools for business to improve both administrative efficiency and underlying economic performance. There are clear benefits likewise to HMRC's administration of the tax system available from properly developed and implemented digital processes. ACCA also believes that a poorly timed or rushed implementation of digital tools could fundamentally compromise the effectiveness of the changes.
Availability of HMRC resource to properly support the taxpayer population through introduction of this HMRC initiative will be vital to success, as will the availability of the third party products on which HMRC and taxpayers must rely.
HMRC and Ministers should make every effort to ensure that new obligations are not imposed until taxpayers, software houses and HMRC themselves are all in a position to implement the end-to-end process at a level which will offer clear benefits to all concerned.
Our detailed comments can be found in the document below.