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2021 Tax Representations

We publish our responses to consultation exercises by the revenue departments as tax representations. They are numbered sequentially in the year of publication, ie ICAEW REP number/year Title.

ICAEW REP 86-21 Notification of uncertain tax treatments

Draft legislation and guidance implementing the government’s plans for large businesses to report uncertain tax positions will introduce additional complexity and not provide the clarity taxpayers need, ICAEW warns in its response to HMRC's consultation.

ICAEW REP 85/21 Promoters of tax avoidance schemes

Draft legislation aimed at tackling promoters of tax avoidance schemes includes subjective terms and tests which are open to interpretation, says ICAEW in its response to HMRC's consultation. The terms should be amended or HMRC guidance created outlining its interpretation to avoid confusion.

ICAEW REP 77/21: Basis Period Reform

Pushing through proposals to change basis periods ahead of the expansion of Making Tax Digital will cause as many problems as it solves and would be a backwards step for affected businesses, warns ICAEW in its response to HMRC's consultation on aligning basis periods with the tax year. ICAEW has urged the government not to implement to proposals.

ICAEW REP 70/21 Simplifying the VAT land exemption

The Tax Faculty believes that simplification of the VAT system for land and property is highly desirable and that consideration is given to removing the current VAT exemption rules for commercial property. However, now that the UK has left the EU, as land and property is only one aspect of the complications caused by the exemption regimes more generally, we think that the time has come to undertake a thorough review of the VAT exemption rules with a view to its abolition.

ICAEW REP 66/21 Timely payment

In responding to HMRC's call for evidence on timely payment, ICAEW argues that earlier payment of income and corporation tax should not be considered until the economy has recovered and that earlier payment should not be based on in-year estimates without HMRC first demonstrating that they can be a reliable basis for earlier payment.

ICAEW REP 65/21: Tax Administration Framework Review

In responding to HMRC's consultation on the Tax Administration Framework Review ICAEW argues that the starting point of such tax reform should be significant simplification of the underlying tax rules and that HMRC needs to be given the resources and funding to give it the capacity to take on such a major piece of work.

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