Recently Her Majesty's Revenue and Customs (HMRC) introduced a register for Accounting Services Providers (ASPs) - auditors, external accountants (any person who by way of business provides accountancy services) and tax advisers - whose business is not supervised by a designated professional body.
All such individuals are required to register by 1 October. However, given that this is an HMRC edict, nothing is ever quite that simple. HMRC have added an "administrative deadline" of 1 July for the receipt of applications to ensure processing; remember we work for the convenience of HMRC, not the other way around.
In the event that an ASP is not registered by 1 October, then that ASP will not be able to trade legally.
HMRC have added a little extra piquancy to their proposal, by levying a registration fee of £95. I guess that if this scheme works well, HMRC will add "registration" fees to a number of other tax areas eg; buy to let landlords, company directors, self employed etc the possibilities of HMRC making money out of "registration" schemes are endless.
In fact HMRC have already come up with an additional fee, how surprising!
Where the ASP provides Registered Office facilities, and/or provides company formation services and/or company secretarial services, there is an additional fee of £50.
This fee entitles the ASP to a "fit and proper test". Contrary to the title, this is not some form of medical assessment. The "fit and proper test" ensures that the ASP is known to HMRC by the ASP supplying the following information; NINO, Passport Number, UTR Number, VAT Registration Number and Bank Details.
So that everyone is clear as to what is happening here, let me summarise, the HMRC are to charge £50 for making an ASP do all the "leg work" of providing details that probably HMRC already have anyway.
The question arises, why don't the ASPs charge HMRC for the time and trouble that they will have to expend in gathering/submitting information to HMRC?
We can assume that all of this information will then be collated onto a CD, which will then be "lost".
Some of you may be asking, aside from the obvious revenue generating potential of this scheme, how HMRC is justifying this to the ASPs.
HMRC's official rationale for this is to minimise the risk of tax/accounts professionals being involved in money laundering, and with international terrorists. An interesting justification, unfortunately it does not stand up to rigorous intellectual scrutiny.
What dishonest, money laundering, terrorist ASP will ever apply for registration with HMRC in the first place?
This scheme will simply cost ASPs a lot of time, effort and money as they scrabble around trying to satisfy another pile of unnecessary questions from HMRC. It is of course a nice little earner for HMRC, aside from the registration fees, they will also make a killing with fines as individuals struggle to comply with the reporting requirements.
This is a stealth tax!
Tax does have to be taxing.
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