United Kingdom
18/04/2024
Further to the government’s 10-year tax administration strategy published in 2020, today marked the 2024 Tax Administration and Maintenance Day (TAM day). In this insight piece, Amanda Tickel and Claire Galineau provide context to this day, details of what was announced and reflect on where this leaves the UK tax policy landscape.
Context
The 2023 TAM day was comprehensive, with the government making 23 key announcements. The new proposals of last year were split into three categories: 1/ Simplification and modernisation, 2/ Tackling the tax gap and 3/ further tax policy and administration announcements. There were two consultation outcomes and one summary of responses published, alongside 11 new consultations and calls for evidence.
In contrast, today, no consultation outcomes or summaries of responses were published, and only one new consultation was released along with some signposting of future announcements.
TAM day announcements
1. New consultation on the VAT treatment of Private Hire Vehicles (PHV)
This newly published consultation was expected and is a welcome development to provide clarity around the VAT issues associated with PHV in terms of whether the suppliers are operating as principal or agent, and the VAT accounting treatment thereof.
2. VAT Treatment of Charitable Donations
A new consultation on the VAT treatment of charitable donations and a relief for low value goods has been promised before 23 July 2024, aimed at supporting the charitable sector by providing further guidance and clarity.
3. Mandating Postcode provision for Freeports and Investment Zones NICs reliefs
The government has announced it intends to introduce a legislative change to mandate a requirement for employers to state the postcode of the workplace on returns where employers claim NIC relief from 6 April 2025. This will be an additional administrative step to accommodate, creating a control measure on claims.
4. Tackling Non-Compliance in the Umbrella Companies Market
As trailed last month at the Spring Budget, the government has issued a statement indicating an intent to publish more HMRC guidance and an online tool aimed at workers who want to check whether the correct deductions are being made. There’s no formal response yet to the consultation from last summer, which means no concrete proposals at this stage.
Reflections
Compared to previous TAM days, today’s announcements were sparse. It is worth noting that significant announcements are being made and consultations are still being released, just not through this channel. The Spring Budget was only 6 weeks ago and included five new consultations. We then had draft legislation published for consultation on 14 March on improving the data HMRC collects from its customers and the future UK Carbon Border Adjustment Mechanism consultation which we’ve covered here. This did not leave much to be announced today. There are over 60 consultations and reviews that remain open, some of which cover policy areas that have been under consideration for years; the net position is that more consultations are opened each year than concluded – which results in uncertainty as to the future of the UK tax system.
On a positive note, the government is seeking to simplify the tax system by abolishing whole regimes or taxes. This was the case at the Autumn Statement 2023, with the abolition of the Offshore Receipts in respect of Intangible Property (ORIP) from 31 December 2024 and the abolition of Class 2 self-employed National Insurance liability from 6 April 2024. This policy intent progressed further at the Spring Budget 2024 with the abolition of the Multiple Dwellings Relief, the Furnished Holiday Lettings and the non-domiciled tax regimes.
But, that said, we’ve also seen new taxes added to an already crowded tax system in the last few years with the plastic packaging tax, the energy profits levy, the electricity generator levy and the new investment zones. And only at the Spring Budget, three new taxes were announced: the duty on vaping, the UK CBAM and the new regime to replace the non-domiciled rules.
In conclusion
It was disappointing that some of the open consultations and reviews were not concluded, and despite only one new consultation being published, it’s important not to lose sight of those that are being announced through other channels and throughout the year. We’re tracking the progress of open policy areas here in our (increasingly comprehensive) Tax Policy Map.