In its response to the consultation, ICAEW notes that HMRC is facing multiple demands on its resources and investment in the coming years. Therefore, this project needs to be assessed against competing priorities.

Feedback received from ICAEW members suggests that while the new platform would be used by businesses, its perceived usefulness would be limited by its proposed functionality. In particular, the current plan for the platform does not include the ability to:

• make and view payments;
• view tax or rates calculations and challenge them where appropriate; or
• link rates liabilities with profitability and target reliefs.

ICAEW recommends that as long as HMRC incorporates these additional functions into the platform in the future, the proposals could prove a useful foundation.

Introducing the new platform would mean that ratepayers must provide additional upfront data to enable the government to identify businesses and tie up their rates and tax information.

Of the three options proposed, ICAEW favours "option A", which involves the ratepayer providing one of its tax reference numbers to the Valuation Office Agency (VOA) as part of the forthcoming requirement to provide additional information to support more frequent business rates revaluations.

ICAEW advocates a single compliance regime that covers both processes. The VOA system would need to be designed so that every user would be able to provide a tax reference or claim an exemption from doing so.

The customer support model will need careful consideration so that business rate payers know where to direct queries: either HMRC, the Billing Authority or the VOA. A potential pilot should also consider this aspect.