CIOT and ATT comment on Draft legislation: The Value Added Tax (Amendment) Regulations 2018

Released 09 February 2018

The CIOT and ATT have published comments sent to HMRC on Draft legislation: The Value Added Tax (Amendment) Regulations 2018.

The submissions comment on the draft Value Added Tax (Amendment) Regulations 2018, as well as the draft Explanatory Memorandum to those Regulations, the draft VAT Notice on Making Tax Digital (MTD) for VAT, and the draft Addendum to that draft VAT Notice, which were all published for consultation on 18 December 2017.

The Chartered Institute of Taxation (CIOT) states that it remains concerned at the timing of the changes which are due to coincide closely with the UK’s exit date from the EU and which also allow insufficient time for proper testing of software. The CIOT considers the benefits of mandatory MTD appear exaggerated and the costs to businesses understated and suggests HMRC consider the two key elements of MTD for VAT (digital record keeping, and submitting the return digitally) separately; perhaps mandating digital record keeping for businesses first, with the requirement for digital links and VAT return submission potentially following later.

The Association of Taxation Technicians (ATT) submission comments on specific areas of the MTD for VAT requirements, with reference to the content of the Regulations, the Notice and the Addendum, as well as their further observations on each of the MTD for VAT documents in turn.

View the submissions:

Draft legislation: The Value Added Tax (Amendment) Regulations 2018 - CIOT comments.

MTD for VAT Regulations - ATT comments.

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