CIOT letter to the Inland Revenue Compliance Office, sent on 1 October 2003, follows. Your publication of exchange rates for many countries, expressed as an average across the fiscal year, is greatly appreciated and of great assistance to our members in preparing personal tax returns. With reference to the foreign exchange rates you published in July for tax year 2002/03, there are a few points which we suggest could merit consideration for future years:
1. Against each country in the euro zone you put the name of the currency that existed prior to 1 January 2002, without any reference to the currency that was the legal tender throughout the tax year for which you were giving the figures.
2. The euro itself could, we suggest, usefully be put at either the beginning or the end of the list, rather than being in an alphabetical listing against a country shown as “Eec”.
3. The list of countries chosen for publication is, perhaps, a product of history rather than present circumstances. We note that no entries are made for, inter alia:
- The constituent parts of the former Yugoslavia, and
- The constituent parts of the former USSR, other than Russia.
4. By July, a fair amount of work on individuals’ tax returns will have already been undertaken. As, we assume, this list is put together electronically, would it be possible for it to be published immediately after the end of the tax year? An early publication date would not only assist the early preparation of tax returns but also enable the list to be used to calculate entries required on form P11D, which an employer is required to submit by 6 July.
5. The absence of capital letters for the names of countries is idiosyncratic.
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