We are committed to contributing to any debate that directly affects the legal and regulatory framework within which the Association and our members work.

All downloads are Word documents unless otherwise stated.

2010

Meeting the obligations to file returns and pay tax on time (HMRC consultation)
This consultation document proposed bringing Indirect Taxes and Excise Duties into alignment with the late filing and late payment regime. The AAT recommended that HMRC pay taxpayers a supplement, equivalent to the penalty, where HMRC is slow in handling repayments and fails to meet its service standards.

Interest - Working Towards a Harmonised Regime (HMRC consultation)
The consultation document is proposing to bring Corporation Tax and Petroleum Revenue Tax into the harmonised interest regime. We believe the harmonisation of interest across the heads of duties will lead to greater clarity for taxpayers and as a consequence will lead to increase compliance, without an increase in tension within the industry.

 Schedule 56 Finance Act 2009 Technical Guidance (HMRC consultation)
Ian Whyteside, the AAT representative on HMRC's Employer Consultation Forum, drafted a response to the HMRC consultation on Schedule 56 of the Finance Act 2009. We made a number of recommendations to improve the process. The response is in the format requested by HMRC.

Objecting to a registered office address (BIS consultation)
The consultation document raised the issue that 18 cases a month arise where the 'legal occupier' objects to the address being used as the registered office. The AAT's proposals would give greater powers to Companies House to act swiftly in protecting the rightful interests of the person and the company and we consider that our proposals will act as a deterrent to unscrupulous companies and vexatious complainants.

Notices of Auditors leaving office (BIS consultation)
The AAT is not an audit authority and has no vested interest in the outcomes of this consultation. Nevertheless, we participated in this consultation as part of our contribution towards the public benefit of achieving sound administration of the law. Users may be interested in the information required to be provided to Companies House by companies when auditors leave office.

 FA09 Schedule 48 (HMRC consultation)
Schedule 48 of the Finance Act 2009 covers the "Extension of information and inspection powers". The AAT's interpretation of schedule 48 does suggest that the guidance in this section does not appear to be in keeping with the legislation. The AAT's response to this consultation is in the format requested by HMRC.

Policy Proposal: The future of UK GAAP (ASB consultation)
The AAT did not support the Accounting Standards Boards' proposals. In stark contrast we welcomed the introductions of the IFRS for SMEs, recommended that the FRSSE become obsolete sooner rather than later and recommended the use of the IFRS for SMEs "with reduced disclosures" for small companies.

2009

  AAT Response to the Consultation on Draft guidance on appeals and reviews
AAT Response to the Consultation on the adoption of International Standards on Auditing
  Exposure Draft - Framework for non-public entites
AAT Response to the HMRC - Compulsory online filing of PAYE + NICS
AAT Response to the HMRC - Compulsory online filing of VAT returns
  AAT Response to JVCC - VAT Change of Standard Rate - Anti-forestalling Legislation
AAT Response to the Payments repayments and debt Feb 2009
AAT Response to Working with Tax Agents
AAT Response to the HMRC consultation on Extra Statutory Concessions

AAT technical accountancy consultation responses 2008

HMRC consulted on a Charter setting out the rights and responsibilities of customers. The AAT responded to this and a signficant number of our recommendations were included.

To see the AAT's response and HMRC's final document outlining the Charter, please refer to the documents below.

• AAT Response to the First tier tribunal tax chamber rules 2009 - Jacqui Brennan
• AAT Response to the Future regulation of VAT invoicing
• AAT Response to the HMRC Consultation on Modernising PAYE Processes for Students
• AAT Response to the HMRC Notes rewrite of S1 20 - Andrew Walls
• AAT Response to the HMRC obligations to pay and file on time
• AAT Response to Interest Working towards a harmonised Regime
• AAT Response to Simplifying the VAT partial exemption and capital goods scheme
• AAT Response to the HMRC's Charter
• HMRC's final document outlining the Charter
• AAT Response to HMRC on Income Shifting
• AAT Response to HMRC on Payments, Repayments and Debt
• AAT Response to HMRC on Penalties Reform Next Stage
• AAT Response to HMRC on The Secondhand Margin Scheme For Vehicles
• AAT Response to Office of the Third Sector Financial Thresholds In The Charities Acts Proposals For Change

AAT technical accountancy consultation responses 2007

• IFRS for SMEs consultation document (this is a PDF document)
• AAT Response - IFRS for SMEs October 2007
• Giving Certainty to Business
• AAT Response to HMRC on Late Night Taxis
• Office of the Third Sector - Changes to the Accounting and Audit Framework
• AAT Response to HMRC on Payments Repayments and Debt - The Developing Programme of Work
• AAT Response to HMRC consultation on giving certainty to business through clearances and advance agreements
• AAT Response to HMRC on compliance checks
• AAT Response to HMRC on Safeguards for Taxpayers
• Response to draft Public Benefit Guidance
• Response to HMRC discussion on HMRC proposals to enforce online filing requirements and encourage electronic payment (Carter programme
• Response to HMRC consultation - board and lodging adjustment agreement for hotels and guest houses
• Response to HMRC consultation - developing a new management act
• Response to HMRC consultation - modernising powers, deterrrent and safeguards - a new approach to penalties for incorrect tax returns