HMRC Taxpayers Charter: ICPA Response

ICPA Comments on the Draft Charter published February 2020

The ICPA represent over 1,150 small practice Accountants operating within the UK and our members all interact with HMRC on behalf of their clients and themselves.

Our general concern is that in seeking to make the language used easier to understand and read it has undoubtedly diluted the existing standards expected from HMRC whilst not having the same effect on the standards expected from the Taxpayer or their agent.

It does not achieve the goal of making it easier to understand and the only success has been to make it shorter and therefore quicker to read.

The current document is specific as to the users of the Charter namely Taxpayers and HMRC and this makes it very simple to review when uncertain on a point whilst the new Charter uses softer more prosaic language which dilutes the impact.

Question Responses:

1) Do you think the draft charter sets the right standards for HMRC’s service to customers?

A) No. It has diluted the standard in favour of HMRC and the wording seems to try to upset no one and is not certain and firm where necessary. This dilution is made under the pretence of “readability” which frankly is to underestimate the reader.

2) To what extent do you feel the draft charter sets out the areas which are most important to customers when interacting with HMRC?

A) Taxpayers are for the most part compliant and fulfil their obligations their concerns are with day to day problems in understanding, engaging and settling their obligations. The Charter becomes important to them when they have problems with HMRC and this draft in no way addresses this issue other than in platitudes and generalities which is not what one would expect from a Charter

3) How would you like to see HMRC measure and monitor how it is performing against the Charter, including how to listen to feedback and take action on areas for improvement?

A) HMRC needs to report far more and on a far regular basis. How this is to be achieved in times of constraint is the issue and further what needs to be covered is a vast area and needs detailed and separate research. MTD is a prime example with spurious “results” and “responses” being output.

In conclusion we would ask that HMRC reconsider the continued use of the term “customers” which fortunately has not found it’s way into the Draft but which has become commonplace in HMRC’s output and frankly is the only single word the taxpayers are united in loathing.