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AAT policy work - technical accountancy

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.

2012

AAT response to the IESBA breach of a requirement consultation

2011

Response to HMRC consultation document: Business Records check

Response to the ASB Financial reporting exposure draft "The future of financial reporting in the UK and the Republic of Ireland"

Response to HMRC discussion document: The simplification of regulatory penalties

Response to HMRC consultation document: Security for PAYE and NICs

Response to the "Communities and Local Government" consultation document: Revision and consolidation of the Accounts and Audit Regulations 2003 9Sl 2003 No533 as amended

Response to HMRC consultation on the technical guidance covering late payment interest and repayment interest (CH140000)

Response to an invitation by BIS to comment on proposals in respect of the registration of company charges

Response to HMRC consultation document: Improving the operation of PAYE

Response to the Department for Business, Innovation and Skills (BIS) consultation document "A long term focus for corporate Britain: A call for evidence"

AAT Response Establishing the future relationship between the tax agent community and HMRC Sept 11

On 31 May 2011, HM Revenue & Customs issued a consultation document which was the culmination of a period of significant engagement with the accountancy/taxation profession to establish ways to improve the relationship between the tax agent community and HMRC.

AAT has been actively involved throughout this process, and canvassed members' views on the consultation through workshop activities, membership events, and an online questionnaire. AAT's response was submitted to HMRC earlier this month, encapsulating the feedback we received from our members, which was broadly supportive of the proposals, recognising that they should result in an improvement to the levels of service they currently experience. Members however did express significant notes of caution regarding the proposals, highlighting specific concerns that they consider need addressing.

2010

Phase II - Amortised cost and impairment of financial assets (IASB consultation)

The AAT supports a more prudent approach to the valuation of Financial Instruments, particularly in the light of recent global experiences in the financial and banking sectors, although this change of approach does have wider implications.

Severe Hyperinflation (IASB consultation)

The AAT supports the Boards proposal for an exemption to IFRS 1 that would allow an entity that has been subject to severe hyperinflation to measure assets and liabilities at fair value and use that fair value as the deemed cost of those assets and liabilities in the opening IFRS statement of financial position.

Draft legislation on deliberate wrongdoing by tax agents (HMRC consultation)
The AAT understands HMRC reasons for the proposals in this consultation. However, we raised our concerns with regards to the way it was being done and we are working with HMRC to obtain a reasonable and workable solution.

CP10/11: Implementing aspects of the Financial Services Act 2010 (FSA consultation)
The AAT is not supportive of proposals to ban short selling on an ongoing basis.

Scale of costs in successful court actions for debt in England and Wales (HMRC consultation)
An HMRC consultation where they are looking to recover their court costs in successful court actions.

Improving the operation of Pay As You Earn (PAYE) (HMRC consultation)
The AAT expressed concerns about HMRC's proposal to centralise the computation of Income Tax and National Insurance contributions.

Revenue from contracts with customers (IASB consultation)

The AAT was delighted to support the IASB exposure draft, which we feel is a balanced approach to "revenue recognition" whereby the principles and transactions reflect the nature of the contract.

Electronic Money Directive (HM Treasury consultation)
This consultation document looks at the implementation of the new e-money Directive.

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.