'Your Charter' - some final tweaks, please

As explained in our recent article, HMRC are now finalising ‘Your Charter’, with the intention of launching it this autumn.

Although we are now generally content with the draft Charter (which can be found at Annex A of HMRC’s response document following a marathon consultation exercise, we feel some final tweaks are necessary. In the hope that they will be addressed before publication and not get lost in the race to the finishing line, we have now submitted our comments to HMRC.

The points we raised included:

• The description of HMRC’s ‘role’ should not be given more prominence in the main body of the Charter than the comments on rights and obligations – the latter being what the Charter is supposed to be all about.
• We hope that testing of the Charter before its launch will include discussing accessibility requirements with groups who consult with HMRC, for example in terms of meeting disabled people’s needs.
• It might be possible to improve the language used slightly; for instance it may be that using the phrase ‘talk to us…’ is not ideal, as it could be seen as excluding those with, say, speech impairments. ‘Get in touch with us’ might be better.
• The draft Charter refers to representation and states in the detail: ‘You should always check that your representative has the right experience and knowledge to help you.’ But we would like HMRC to reconsider what this really means – for example, how is a lay person with little knowledge of tax able to check to find out that one representative has the right experience and knowledge or that another representative has not? We also raised this and related points in our response to HMRC’s ‘Working with Tax Agents’ consultation.
• Many unrepresented people are unaware what to ask when contacting HMRC. We have therefore asked that HMRC remove the qualification in bold in this statement: ‘we will…explain why we need information, if you ask us to’. HMRC should offer such explanations without having to be asked as a matter of good customer service.
• In our response to the last round of consultation, we said that the Charter should inspire HMRC to offer a joined-up service, both internally and in terms of working across government. Whilst the revised draft acknowledges that HMRC work closely with the Department for Work and Pensions, we would prefer to see an even wider commitment – after all, HMRC also has working relationships with others such as local authorities and the Student Loans Company.
• Finally, and perhaps most importantly, one of the ‘rights’ in the revised draft is not balanced. It clearly states that HMRC will ‘identify people who are not paying what they owe’. But nowhere does it state that they will ‘identify people who have paid more than they owe’ or ‘repay such people and give them interest where appropriate’. We would like to see this point addressed, even at this late stage.

To read our full response please use the link below.

Contact Name: John Andrews (0844 579 6700 Fax 0844 579 6701)

To open the file click here: LITRG reaction to Charter response