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Tax Advice Call For Evidence Document,
Agent Policy, CIDD,
HM Revenue & Customs,
9th Floor, 10 South Colonnade,
Canary Wharf, London E14 4PU
Raising standards in the tax advice market – Call for evidence
Thank you for the opportunity to participate in several of your public discussions on this consultation. I confirm my views as follows.
There is a need to reignite the importance of professional bodies not regulatory or supervisory bodies; the distinction is an important cultural one.
‘Tesco law’ doesn’t work as a means of setting the moral tone required to underpin good standards.
It is the culture in which advisers operate that is important, not rules which apply penalties. The respect from peers is the greatest driver of good behaviour in a profession.
Our tax oeuvre is overly complex by reason of the profusion and disorganised sources of our tax law and needs to be rewritten into a single digital statute (a “Master Tax Statute”) without additional statutory instruments, statements of practice, guidelines, FAQs and HMRC manuals.
Simplicity by reduction should not be an objective, as therein lies tyranny and some rules will always be inherently complex, but clarity as to the organisation of our tax rules and coherence in the way they are expressed on a consistent basis would be a very worthy outcome.
Words matter. If their meaning slips, shifts or falls out of kilter with the times then adjustment is necessary, but this should be by way of a moving consolidation of a Master Tax Statute.
There should also be a single glossary of all of the defined terms used and hyperlinks within the Master Statute to all decided cases as they are published.
The scope for unscrupulous promoters to operate would be much reduced as a result.
I hope these comments are helpful.