ACCA's response to HMRC Charter. The Charter sets the standard for interactions between HMRC and its customers. We’ve made a number of points including improving customer trust, frameworks for resolving disputes and expertise and training of HMRC staff.
Trust lies at the heart of a healthy relationship between a tax authority and the taxpayers and agents who interact with it. Since 2009 HMRC has positioned the Charter as a central element in building that trust. Stakeholders’ expectations have evolved over time as the legislative framework of powers and safeguards, and HMRC’s interpretation and implementation of those laws, has developed.
Transparency and accountability come up in every forum as being the key to tax morale and good tax engagement. This applies across the board, and tax authorities should be every bit as transparent and accountable as taxpayers and the agents who support them when it comes to paying tax.
Stability is just as important as certainty and simplicity when it comes to the tax system. HMRC should resist the temptation to make changes to the Charter if the problems lie not with the wording but with the implementation. It is not the words of the Charter that matter so much as the public perception of HMRC’s implementation of it. That said, if a revision to the framing of HMRC’s commitment to the Charter highlights the existence and importance of it then, regardless of whether there is an objective need to change the words, that change might function as a clear signal of HMRC’s recognition of the importance of the Charter to public trust in the UK tax system.
It will remain important for the Charter to operate as part of the wider tax compliance environment, and our response to this consultation should be read in conjunction with our input into the Raising Professional Standards strand as well as the wider design of the UK tax system and policy developments. Recognising the changing environment in which HMRC, taxpayers and their advisers operate in, the collaborative development of appropriate timely guidance supporting specific principles of the Charter should be considered as an additional resource.
Please download the consultation response document for the full response.