In his inaugural speech as President of the Chartered Institute of Taxation (CIOT), Glyn Fullelove will today say that high professional standards has the potential to be one of the strongest positive messages in the CTA (Chartered Tax Adviser) brand. He will say there is no place for any tax advisers who promote avoidance schemes in the CIOT.
Glyn is a former Head of Tax for four UK headquartered quoted FTSE 250 or FTSE 100 companies, most recently with Informa plc until September 2018. He was until today Chair of the CIOT’s Technical Committee.
Speaking at the CIOT’s annual general meeting1 this afternoon Glyn will also:
- Say the UK taxes large companies comprehensively and robustly and caution that further changes to how large companies are taxed should weigh any additional yield against increasing complexity in the system
- Emphasise the cultural change over the last decade in how tax is dealt with by UK PLCs
- Suggest that narrowing the tax differential between being employed and self-employed may be needed
- Highlight the Institute’s increasing offer to students and graduates of its ADIT (international tax) qualification
- Set out how the Institute will be exploring the impact of technology on the tax profession during his presidential year
In addition to Glyn Fullelove becoming President, Peter Rayney today becomes Deputy President and Susan Ball Vice President of CIOT.2
On the importance of maintaining high professional standards Glyn will say:
“There is no doubt that trust in the tax profession amongst the general public and politicians of all types was damaged in the aftermath of the financial crisis of 2008. The development of Professional Conduct in Relation to Taxation - to make it clear that members should not create, encourage or promote tax planning arrangements or structures that either set out to achieve results that are contrary to the clear intention of Parliament in enacting relevant legislation or are highly artificial or highly contrived and seek to exploit shortcomings within the relevant legislation - was a necessary step on the road to restoring trust.
“As President of the CIOT I will not hesitate to remind members of their obligations in this area; and if there are still members who seek to develop and promote such schemes, I have a simple message – this is not the body for you.
“However, and more importantly in many ways, PCRT now has the potential to be one of the strongest positive messages in the CTA brand. Our clients should now be sure that advice received from a CTA is not only of the highest technical standards; it is also advice that will not find them locked into disputes with HMRC that could have at least a severely detrimental impact on their reputation, and, at worst, as we have seen with the recent loan charge legislation, have ruinous financial consequences.
“We can’t guarantee of course, that our advice will not be disputed by HMRC, and indeed, we will often wish to dispute HMRC’s view of the law where the intent of Parliament is genuinely unclear. This brings me back to Ray’s work in the last year. Our dialogue with HMRC now often focusses on the benefits to HMRC of them working with agents who are subject to PCRT; and the greater the confidence in the other that both sides can have when dealing with disputes, the more likely it is that both sides will be able to resolve disputes to their mutual satisfaction and without recourse to litigation. Building this confidence will require efforts from both sides, but if it can be done, our clients and the exchequer – which means taxpayers generally – will benefit.”
On taxation of large companies Glyn will say:
“I personally think that taxation of large companies in the UK is now comprehensive and more robust than it has ever been. If further changes along the lines suggested in recent publications from the OECD are to be considered, we need to think very carefully about how complicated we really want to make collecting a tax which amounts to only 7.2% of the total National Account taxes…
“More broadly, it is clear that there has been a cultural change within large multi-national companies, particularly UK based quoted PLCs, in regards to taxation over the last ten years. Boards that may once have only merely noted their effective tax rate, and left it for the finance and tax function to manage as they saw fit, now see tax as a key element of their risk register, and are acutely aware of the reputational impact being seen as “aggressive on tax” can have. In my view, this cultural change has been as important, if not more so, than most legislative change in how UK based PLC Tax Directors have approached their role over the last decade.”
On taxing people not in ‘conventional employment’ Glyn will say:
“One of the most significant changes in our economy in the last decade, which has a profound impact on taxation, is how we work. The days of most people working for life for a single employer seem as distant as the Napoleonic wars, and the rise of self-employment, the gig economy, contracting as a way of life and so on are putting considerable strain on our employment laws and our tax laws.
“So far, the main government response has been a technical one, effectively trying to define employment as widely as possible. What this does not take into account is the fact that, now, many people simply do not regard themselves as being in “conventional employment”, for which PAYE is designed, and this gives rise to an expectation that they should be taxed differently. It’s far from clear to me that what amounts to keep telling people “actually you are employed” is the right solution, and that a much more radical solution, including narrowing the tax differential between being employed and self-employed, may be needed. Whatever is done, we should all recognise that there is a “behavioural” question here, not just a “technical” one.”
On ADIT (Advanced Diploma in International Taxation) development Glyn will say:
“In September, we will be holding our first conference specifically targeted at ADIT students and graduates and our first graduation ceremony exclusively for those who have completed ADIT. Our ADIT working party continues to consider how our ADIT graduates can be more involved in the CIOT, recognising it is a distinct and different qualification to CTA.”
On exploring the impact of technology on the tax profession Glyn will say:
“I am keen for the CIOT to explore the impact of technology on how CTA’s work during the next year, and to consider the implications for the Institute. We will be holding a panel discussion on this at the British Academy on 17th September, with contributions from in-house professionals who are leaders in this area, and I am looking forward to what promises to be a fascinating evening.”
Notes for editors
1. The CIOT’s Annual General Meeting takes place at 4.45pm today at One Great George Street, Westminster, ahead of the CTA Address at the same venue. It is expected to conclude by 5.30pm.
2. CIOT Officers
New President – Glyn Fullelove
Glyn has worked for over thirty years in tax, and is a Chartered Accountant as well as a Chartered Tax Adviser. He qualified with Arthur Andersen, and was Head of International Taxation for Robson Rhodes before moving into commerce. He has had Head of Tax roles at four UK headquartered quoted FTSE 250 or FTSE 100 companies, most recently with Informa plc until September 2018. As well as his CIOT duties, Glyn currently also undertakes freelance tax training and digital publishing work.
Glyn has been active as a volunteer on CIOT technical matters for over fifteen years and chaired the Technical Committee from May 2016 until he became President of the Institute in May 2019. He is well known as a speaker at tax conferences, especially on digital taxation and the taxation of multi-national enterprises.
New Deputy President – Peter Rayney
Peter Rayney practices as an independent tax consultant. His main specialisms are corporate tax, company reorganisations, corporate finance tax (including company sales and acquisitions) and all aspects of owner managed business taxation. Peter worked at BDO LLP for nearly 20 years, acting most recently as their National Tax Technical Partner.
He is a widely-recognised tax author and lecturer and regularly contributes to the professional press. He has now won Taxation's 'Tax Writer of the Year' award an unprecedented three times in 2002, 2014 and 2018. Peter currently chairs the ICAEW Tax Faculty's Technical Committee.
New Vice President – Susan Ball
Susan Ball is Partner and Head of National Employers Advisory Services, Employment Tax/NIC, Reward & Expatriate Tax at Crowe UK LLP. She has been a CIOT Council member since 2017 and is a past Joint Chair and founder member of the CIOT/ATT Suffolk Branch. She is a member of the Institute’s Employment Taxes Sub-Committee. She writes and lectures on employment tax and NIC.