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Single compliance process: HMRC briefing paper

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HMRC have published a briefing paper for tax agents on the trial of a ‘single compliance process’ in 12 UK locations. The trial was set to begin earlier this month but was delayed to allow detailed guidance to be prepared.

The CIOT said that while it was critical of the original plans, it was pleased that HMRC had listened and made changes. HMRC are planning to make a general information sheet available shortly.

The Compliance Reform Forum is helping HMRC to develop what the department regards as a ‘new and improved approach’ to compliance enquiries.

Some compliance processes have already been modified, HMRC said. But there has been ‘a growing concern that, in some circumstances, the changes may not be beneficial for [HMRC’s Local Compliance SME groups] or business and what is needed is an overarching compliance process uniting all our enquiry work’.

The trials will exclude pre-return compliance checks but will involve use of the new process for formal enquiries into SME business returns such as those made under TMA 1970 s 9A; and include assurance work carried out typically for VAT and Employer Compliance.

HMRC believe that the single compliance process will reduce business burden by reducing the time taken to complete enquiries; reduce the time spent ‘per case’; focus the intensity of the enquiry so that it is proportionate to the risks identified; and provide a flexible framework for HMRC staff and business in which ‘joint expectations are clear’.

Intensity

‘We plan to bring 1,100-1,200 cases through the entire process during the trial period, which is about 1% of the total number of enquiry cases administered by LC SME,’ HMRC said.

The briefing paper sets out four different levels of ‘intensity’ for enquiries. At the first level, where there is no need for a face to face meeting, the enquiry is expected to take no longer than 1 to 1.5 days.

The second level will adopt ‘a simplified and faster route’ where a lower intensity face to face intervention approach is required (expected maximum time 2 days). Level 3 will address cases where the depth and breadth of the enquiry is more involved (4 days), and level 4 will tackle ‘the most demanding cases such as those indicating tax evasion characteristics or those highly complex in nature’ (8 days).

HMRC will undertake a ‘mid-point review’ in September and a final review in December, before implementing the new approach in January 2012.

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