Call for evidence on the Council Tax (Substitution of Proportion) (Scotland) Order 2016 - CIOT and LITRG comments

21 Sep 2020


Please complete the survey, which should take approximately 15 minutes, as comprehensively as possible using the free space provided and add any additional comments you may have at the end.

The closing date for responses to the survey is Friday 30 September 2016.

An overview of the Making Tax Digital proposals can be found here. In summary;

From 2018 most businesses, the self-employed and landlords will need to use software or apps to keep their business records and to update HMRC quarterly.

There will be an exemption for all unincorporated businesses and landlords with gross income/annual turnover below £10,000.

HMRC are proposing to defer implementation for a year for a limited group of unincorporated businesses and landlords with annual turnover above £10,000 but below a threshold which is being consulted on.

Those that genuinely cannot use digital tools will not be forced into doing so and they will exempted entirely from the new obligations.

Other groups who feel they should be out of scope can make their case as part of the consultation process.

HMRC are consulting on simplifying some of the underlying tax rules to support the changes being introduced by Making Tax Digital, including extending the ‚ cash basis‚ to larger businesses and property businesses, reforming the basis period rules and simplifying reporting for businesses that use GAAP accounting.

HMRC are consulting on introducing ‚ voluntary pay as you go‚ for businesses and landlords who are keeping their records digitally and providing regular updates to HMRC.

There are proposals to adapt HMRC‚ s compliance and enquiry powers to support the changes being introduced to reporting and filing obligations, and to introduce a new regime for late submission penalties, late payment sanctions and proposals to align interest across taxes.

HMRC are also consulting on how more effective use of third party information can contribute to the transformation of the tax system.

The Treasury Press Release issued on 15 August 2016 can be found here. The Press Release included a favourable comment from Mike Cherry, National Chairman of the Federation of Small Businesses, on the changes made to the original proposals and the story was widely picked up in the media including in the 14 August Sunday Times under the headline ‚ Taxman‚ s U-turn over online filing for small businesses.

The CIOT issued a press release welcoming HMRC‚ s decision to exempt many small businesses and the digitally excluded from the Making Tax Digital reporting requirements, but cautioned that the proposals remain very ambitious and wide ranging. ATT‚ s press release reiterated its call for a change to the timetable for the implementation of quarterly digital reporting despite the welcome concessions to small business.

Links to the 6 consultation documents are provided below:

Making Tax Digital: Bringing Business tax into the digital age (including digital record keeping and quarterly reporting requirements)Making Tax Digital: Tax administration (including compliance powers, late submission penalties, late payment sanctions and interest)Making Tax Digital: Voluntary pay as you goMaking Tax Digital: Transforming the tax system through the better use of information (third party information)Simplifying tax for unincorporated businesses (including increasing the entry threshold to the ‚ cash basis‚ , reforming the capital/revenue divide inside the ‚ cash basis‚ , reforming basis periods for all self-employed sole traders and simplified reporting for businesses using GAAP accounting)Simplified cash basis for property businesses

If you have any specific comments on any aspect of the consultations, please email them to the CIOT Technical Team at technical [at] or the ATT Technical Team at atttechnical [at]

Click here to complete the survey

Thank you for your support.