Ensuring that legislation is well drafted and that issues arising post-implementation are picked up quickly is key in ensuring that measures achieve stated policy aims. It also is crucial in safeguarding that taxpayers have confidence in the UK tax system and in HMRC’s ability to administer that system in practice.
In our opinion, the publication of draft Finance Bill clauses for open consultation has been both a welcome and a successful step. It allows for greater input from taxpayers and advisers before a measure becomes law, and we hope that the Government continues this practice. However, although we would encourage the Government to follow the full consultation framework wherever possible, not all measures can be published in advance in this way. Furthermore, even extensive advance consultation may not pick up practical issues (both for taxpayers and HMRC) which only become clear as new legislation takes effect.
We would, therefore, have suggested the following changes to improve the policy making and implementation process: