The Association offers specific comments in response to this consultation by HMRC on The Tax Administration Framework: Supporting a 21st Century Tax System but would like to offer overarching thoughts based upon the Association’s Guiding principles of good tax policy: A framework for evaluating tax proposals (“Guiding Principles”).
Any suggestion for modifying tax rules — whether major or minor — raises the question of how to best analyse and compare proposals. A framework based on appropriate tax policies is needed