Timely payments in Income Tax Self-Assessment (ITSA)
ACCA responded to HMRC’s consultation on more timely payment of ITSA liabilities. While supporting the objective of assisting taxpayers with managing their tax obligations, ACCA believes greater value can be realised by enhancing the voluntary payment regimes already in place. There are also other cost-effective mechanisms capable of achieving the desired outcome. Given that viable alternatives exist, ACCA is most concerned about the administrative burdens that will inevitably arise from creating a system that seeks to cater for all taxpayers.

Requiring payment of VAT and PAYE – direct debit
While ACCA commends HMRC efforts to consider areas where simplification can lead to further efficiencies, we do not support the proposal to make payment by direct debit ‘mandatory’ for VAT and PAYE in most cases. HMRC has acknowledged in the consultation document that ‘late payment is often linked to oversight or payments being allocated incorrectly rather than an inability or unwillingness to pay’. We would note that a payment made on time that is incorrectly allocated by HMRC is not a late payment.

Introducing a criminal offence for making reckless untrue statements or declarations in direct tax
We recognise the government’s objective to strengthen the integrity of the tax system, and agree, in principle, that targeted sanctions for serious misconduct can lead to greater consistency, proportionality and deterrence across the UK tax framework. However, the complexity of tax legislation and the use of voluntary compliance mean that any new offence must be carefully designed and implemented to support honest taxpayers and advisers, while concentrating criminal liability on those who consciously disregard risks or act with deliberate dishonesty.

Extending VAT online marketplace liability to combat non-compliance
We recognise the government’s objective to combat VAT fraud and non-compliance. This includes making online marketplaces more accountable for ensuring that sellers using their platforms comply with VAT obligations. However, we have a number of significant concerns and observations about HMRC’s proposed approach.

Play your part

ACCA responds to a number of consultations during the year and member insights and comments play a vital part in these responses as they affect the profession as a whole.

If you have any particular feedback or case studies that would be useful for our responses, please contact us on UKPolicy@accaglobal.com.