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I can’t imagine that readers will have spent much time reading the recently published ‘memorandum of understanding: accessing HMRC information to assist Foreign, Commonwealth and Development Office honours committees in making recommendations about awarding honours to individuals’ (tinyurl.com/hmrchonsfcwo). Indeed several similar documents have appeared on the HMRC website, dealing with communications with various honour awarding bodies.
Much of the document is concerned with the protocols of information sharing. This is important but frankly rather tedious. But at the end is an interesting section in which HMRC sets out what it considers to be low, medium and high-risk behaviour: it gives one of these flags to the honours committee – it doesn’t pass on detailed information.
Much of what is said here is to be expected but a few things I did find surprising. The first is that somebody with a history of tax avoidance or evasion that relates to a tax year more than three years ago where liabilities have been fully settled can be considered low risk and not likely to cause adverse public comments. Some might regard that as a lenient approach to comparatively recent evasion. By contrast, somebody with an open enquiry where employment status is an issue and where there is deemed to have been careless behaviour is in the medium risk category. Given how difficult it is to show that errors were not careless that seems quite harsh.
It is right that in an era of openness HMRC does publish these guidelines – I hope that they will be kept under review and tweaked when appropriate.
If you do one thing…
Read the agreement about exchange of data between HMRC and Companies House (tinyurl.com/hmrcdatausage). Does annex B give you any problems?
