The CIOT is concerned that the ‘sandbox’ piloting approach in the consultation document The Tax Administration Framework Review: Creating innovative change through new legislative pilots as a new way of testing changes to legislation could give rise to problems particularly if it were to be run as a parallel tax or penalty system rather than treated as a trial involving a small number of taxpayers.
CIOT believes that sandbox should not be a short cut to enacting or introducing new rules without any external scrutiny nor should it remove the need for proper piloting where there is a large scale system change such as with making tax digital. Its importance is to assess whether a policy idea is workable and likely to have the desired effect before it becomes ‘baked in’ and consequently harder to deviate from.
The concern is also that those...
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