The CIOT is pleased to contribute to HMRC’s consultation on landfill tax which is seeking to assist those accounting for landfill tax with clarity in understanding the scope of the tax and reliefs available. This has been a particular issue for the waste disposal sector since the previous legislative change in 2009.
The CIOT welcomes HMRC’s commitment to simplify the landfill tax rules but is concerned that by limiting its consideration to exemptions based on existing guidance there is a risk of continued confusion and potential ongoing challenges to the application of the tax.
Ideally the terminology and areas of engineering works qualifying for future relief will be aligned as far as possible to existing environmental regulation and industry practice. Adequate definitions will be necessary to make it clear exactly what landfill site works will qualify for exemption.
The consultation also seeks to remove the potential for waste classified as hazardous to qualify for lower rating landfill tax. The CIOT agrees that in principle all hazardous waste should be subject to the standard rate of landfill tax.
We believe for environmental taxation to be fully effective in changing behaviour, it is necessary to have clear objectives of what an environmental tax is intended to do. We have previously raised concern that there is a lack of clarity around the general direction of environmental tax policy. For this reason, we call on the Government to put in place an Environmental Tax Framework, or road map.