We have collated a summary of ACCA consultation responses to support you in your future day to day work. We value the feedback and insight that you bring so please send us your comments and views on this summary and future consultations.
ACCA’s Response to the Comprehensive Spending Review 2020 – 24 September 2020
Government must use accounting information to support data-driven decision making and public service outcomes. Government should now ‘take a balance sheet approach’ to managing public finances and set benchmarks for new fiscal targets aimed at creating a more inclusive and greener future.
ACCA supports the return of Enterprise Finance Guarantee to give business continued confidence around access to finance as CBILS is phased out. ACCA research found only 27% of businesses revisited business plans in light of Covid-19 and businesses may not be aware of their financial risk in the coming 6-12 months. Businesses will need a reliable successor loan scheme to ensure they can access finance.
ACCA advocates for better use of Local Enterprise Partnerships (LEPs) help local businesses access professional advice. Many businesses may be at risk as debt repayments become due over the next 12 months. ACCA supports enhanced funding for LEPs to offer SMEs in financial distress free initial consultations with accountants to provide advice on financial forecasts and improve financial sustainability.
The spending review must consider strengthened powers for the Small Business Commissioner in order to tackle Late Payment issues. During Covid-19, 65% of businesses have experienced an increase in late payment and this spending review presents a well-timed opportunity to reinforce the powers of the Small Business Commissioners Office to tackle late payment.
The recapitalisation of UK businesses is a key priority for government and industry, and ACCA welcomes the government’s move to extend loan scheme terms to support business cashflow. The creation of a non-departmental Recovery Corporation or similar should be considered to manage the administration on the volume of recapitalisation and restructuring.
ACCA’s Response to HMRC’s Consultation on Raising Standards in the Tax Advice Market - 28 August 2020
ACCA does not support additional professional body supervision of non-professional body member tax agents. Additional regulation may not be the most effective way to target poor behaviour. Although it may present an added deterrent, it is our view that those that offer unethical or bad advice do so in the knowledge that they are acting outside of the spirit of the tax regime which they seek to exploit.
While HMRC expects all tax agents, including unqualified agents, to comply with HMRC’s ‘Standard for Agents’, the scope of this does not fully replicate professional body standards. It continues to be difficult to enforce standards across the board when agents are not required to have a similar standard of qualification and regulation by professional body. In principle, therefore, it should be easier to maintain high standards and thereby improve taxpayer compliance if all tax agents are appropriately qualified.
ACCA invites further discussion with HMRC on ‘kitemarking’ or similar and improving assurance for customers and the standards of tax advice offered by qualified advisers.
ACCA’s Response to HMRC’s Consultation on the HMRC Charter: 14 August 2020
Language around the right of taxpayers to have appropriate representation has changed from the previous Charter. Individuals and businesses often require professional support to set up account details with HMRC, check calculations and use office tax portals and will frequently engage a professional agent specifically to deal with all tax obligations. Wherever possible, ACCA recommends that the Charter allows taxpayers to exercise that right to representation at every possible opportunity.
Members have expressed a concern that taxpayers assume that in the absence of any acknowledgement of fault from HMRC, it must be the agent who is at fault. This damages the taxpayer/agent/HMRC relationship and is detrimental to long term tax morale. Acknowledgements of error as standard from HMRC would build greater trust and raise the standard of the overall system.
The Charter must include additional clarity on HMRC’s commitments to reviewing and taking action on failures to act in accordance with the Charter. It is ACCA’s view that this will grant customers greater confidence in HMRC’s institutional drive for accurate information and fair conduct. HMRC’s measurement against the Charter must be visible, measurable and supported by verifiable evidence. If HMRC is not reaching its own standards, then it must acknowledge this and explain clearly what steps are going to be taken to remedy that, how they will be assessed and when and how HMRC will publish the results of the assessment.