Friday, August 01, 2014


BLOG 152

I am a big fan of Lewis Carroll.  Most of us think of Alice through the Looking-Glass and its sister volume, Alice in Wonderland as children’s stories, but many scholars believe that they have far deeper meanings.  I think however that I am probably the first to surmise that when Rev Dodgson caused Humpty Dumpty to utter his immortal statement, “When I use a word, it means just what I chose it to mean – neither more nor less”.  To which Alice of course retorted, “The question is whether you can make words mean so many different things” and received the response, “The question is which is to be master – that’s all”.

I do a lot of reading.  In particular I read a great many HMRC and Treasury consultation documents.  I think that my insight that Humpty Dumpty is modelled on a civil servant has been growing gradually, but I have been prompted to put forward my theory after reading an HMRC consultation, “Improving the Operation of the Construction Industry Scheme (CIS)”.

This tells us that “The Government’s digital strategy is to offer high-quality, convenient and up-to-date services so that those using them become digital by default.  By this we mean digital services that are so straightforward and convenient that all those who can use them will choose to do so whilst those who cannot are given support to ensure that they are not excluded” (para 3.5).  I understand that to mean that the services will be so good that, faced with a choice of communicating digitally or by post, everyone with access to a computer will choose digital.

But that is not what “will choose” means in HMRC’s Looking-Glass world.  They go on to explain, “Many of the benefits of system improvements would only be fully realised if all CIS returns were made online.  We are therefore proposing to mandate online filing”.  I take that to mean we are not going to let people choose at all; we will force them to use the digital channel.

HMRC also say (para 3.4) that, “internal analysis of a small sample of those continuing to file paper CIS returns [which is 30,000 businesses] shows that those contractors do have access to a digital channel and are complying with other HMRC filing obligations through online channels”, i.e. 30,000 people currently choose not to file online, presumably because either they do not trust the system or find it too cumbersome.  In a non-Looking-Glass world one might expect some further research in this area to understand why.  It is only in a Looking-Glass world that the Nanny State would force people to go online against their will for their own good.

At least I assume it is for their own good, as in the Forward to the consultation, the Minister, David Gauke, says, “This consultation sets out proposals for improvements to CIS online services for contractors …  These proposals could substantially reduce CIS businesses administrative costs”.  The document does not actually consult on many proposals.  It tells us that a system upgrade is needed as the current system was not designed to handle today’s volume of contractors using it.  It also says that one option being examined is the Real Time Information channel, and that it is considering an online appeals service to enable people to appeal immediately when the computer imposes a penalty, with the computer then deciding whether to cancel the penalty, presumably because it will be so efficient that it will be able to determine that it wrongly imposed the penalty in the first place.

I have largely managed to steer clear of RTI, but I understand that HMRC’s rosy view of it is not universally shared and that there are still a lot of unsolved problems.  In 2006, Lord Carter’s 2006 Review of HMRC Digital Services recommended “HMRC should benchmark customer satisfaction with its online services against commercial online services and seek to learn from best practice”.  It also recommended that, “Each of the services should be capacity tested at least a year before our recommendations are implemented and if any tests are not successful, the measures relating to that service should be deferred”.  Lord Carter is not a civil servant so I can be fairly confident that he meant that, like commercial software companies, HMRC should release a beta version and after testing should refine it so that the system works as intended.  I’m pretty sure that he did not mean that HMRC should release a beta version, see what problems it throws up, and decide whether it can live with those problems that cannot be readily fixed and, if so, let’s go ahead and force taxpayers to cope with them.  But in HMRC’s Looking-Glass world that is how they seem to have interpreted the recommendations.  In any case, that was 8 years ago and Lord Carter is no longer involved.  I doubt that any commercial software supplier would have had the nerve to introduce RTI in its current state.  So forcing CIS contractors to use it too can be an improvement only in Looking-Glass world, not in the real world.

An online system under which the computer automatically charges penalties, the taxpayer explains on-line why he believes no penalty is due and the computer then cancels it, may be an improvement on the current system under which the computer imposes a penalty automatically, the taxpayer writes a letter and a human being decides the penalty is not due and cancels it, but I suspect that I am not the only one to think that a better system would be for no-one to charge a penalty unless it is actually due.

I think that the Looking-Glass explanation can be found in 3.9.  Mandatory online filing “would also enable HMRC to make substantial administrative savings”.  In other words, the real world, this is not actually about “reducing CIS businesses administrative costs”; it is about reducing HMRC’s administrative cost, however much inconvenience it might cause to CIS businesses to achieve that.

I could go on, but I hope I have done enough.  QED.  Humpty Dumpty must have been a civil servant!



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