Opinion Former Article

Institute welcomes promise of more early policy consultations

The Chartered Institute of Taxation (CIOT) has welcomed a government promise to hold more early stage policy consultations and to reintroduce the online tax consultation tracker.

The commitments are made in a policy paper published this afternoon by HM Treasury - The new Budget timetable and the tax policy making process.1 The paper also confirms what the new consultation process around a single fiscal event (the Autumn Budget) will look like.

CIOT Tax Policy Director John Cullinane said:

“This is a very helpful document which sets down in writing the government’s commitment to further improvements to the process for making tax policy.

“In particular we welcome the commitment ‘to consult more frequently from an earlier stage of policy development’2. More early stage consultation was a central recommendation of the Better Budgets report, published in January 2017 by CIOT, the Institute for Government and the Institute for Fiscal Studies.3

“Too many consultations begin when key decisions have already been made, shutting off potential better options to achieve the same goal. Calls for evidence, like the one launched last week on ‘rent a room relief’, and early stage consultations, such as that on corporate tax and the digital economy, launched on Budget day, are hopeful early signs that the government will be doing more early consultation, getting input from business, tax professionals and others to inform the process before a proposal has been drawn up.

“A regularly updated tax consultation tracker is something else we have been making the case for, both in Better Budgets and in ongoing discussions with Treasury and HMRC officials. We are pleased that the government have confirmed their intention to re-introduce such a tracker, and we look forward to the promised further details before the end of 2017.4

“The Government’s recommitment to just one fiscal event a year – with the ‘Spring Statement’ having a more limited role – is welcome. The move to a single fiscal event is something the CIOT and our Better Budgets partners had argued for. We believed that it would enable more time to be spent on consultation and scrutiny and would reduce the strain that two big fiscal events a year put on government and consultees alike. This isn’t just about enabling organisations like CIOT to do more. It offers more opportunity for outreach to bring in views from a wider range of consultees.”

However CIOT has identified areas where the government could go further. John Cullinane continued:

“Parliamentary scrutiny of tax legislation still has a lot of scope for improvement. In particular we believe oral evidence sessions before Finance Bill public bill committee, bringing in both expert witnesses and representatives from groups affected by particular changes, could lead to better-informed policy-making. This has cross-party support in Parliament yet the Government seem reluctant to allow it.

“Also, the consultation process should not end with the passage of legislation. There is room for more effective and systematic post-implementation reviews to determine whether measures are achieving the objectives set out for them.”

Notes for editors

The government paper can be read here.

“[T]he government already routinely consults on the detail of tax policy changes once they have been announced. But the new tax policy making cycle provides an opportunity to consult more frequently from an earlier stage of policy development.
“Calls for evidence and early-stage consultations allow open development of policy options and the evidence base within a broad area of the tax system. They are particularly valuable and appropriate where a large-scale reform is under consideration, where options are not readily defined, or where existing information is limited…

“The opportunity for early consultation will always need to be proportionate and balanced against the government’s responsibility to manage the public finances- including the risk of forestalling. But for major or longer-term tax policy changes, the government aims to consult, where possible, at an earlier stage.”

The new Budget timetable and the tax policy making process, HM Treasury, Dec 6 2017, section 3.1

“Step 4: Start consultation at an earlier stage
“Too many consultations begin when key decisions have already been made, shutting off potential better options to achieve the same goal. The Government should consistently stick to its commitments in The New Approach to Tax Policy Making. It should also start consultations by setting out and obtaining views on different options, or by putting out calls for evidence to allow it to gain the widest possible understanding of an issue.”

Better Budgets, CIOT/IFS/IfG, Jan 2017, page 4


“The government will also re-introduce an online consultation tracker, so stakeholders can see where in the policy development cycle each measure is, and when consultation will take place. Further details on this will be set out before the end of 2017.”
The new Budget timetable and the tax policy making process, HM Treasury, Dec 6 2017, section 3.2

The Chartered Institute of Taxation (CIOT)

The CIOT is the leading professional body in the United Kingdom concerned solely with taxation. The CIOT is an educational charity, promoting education and study of the administration and practice of taxation. One of our key aims is to work for a better, more efficient, tax system for all affected by it – taxpayers, their advisers and the authorities. The CIOT’s work covers all aspects of taxation, including direct and indirect taxes and duties. Through our Low Incomes Tax Reform Group (LITRG), the CIOT has a particular focus on improving the tax system, including tax credits and benefits, for the unrepresented taxpayer.

The CIOT draws on our members’ experience in private practice, commerce and industry, government and academia to improve tax administration and propose and explain how tax policy objectives can most effectively be achieved. We also link to, and draw on, similar leading professional tax bodies in other countries. The CIOT’s comments and recommendations on tax issues are made in line with our charitable objectives: we are politically neutral in our work.

The CIOT’s 18,000 members have the practising title of ‘Chartered Tax Adviser’ and the designatory letters ‘CTA’, to represent the leading tax qualification.

Contact: George Crozier, Head of External Relations (gcrozier@tax.org.uk / 020 7340 0569) (Out of hours: 07740 477374)

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