Consultation response: Modernising Revenue Scotland’s Tax Administration Framework – Communications with Taxpayers
As part of modernising the administrative framework for Scottish devolved taxes, Revenue Scotland published a consultation to seek views on a proposal that would use electronic communications as the default method of communicating with taxpayers.
Revenue Scotland currently has the responsibility for the collection and management of Land and Buildings Transaction Tax and Scottish Landfill Tax. In the near future, this will be expanded to include the collection and management of Scottish Aggregates Tax, Air Departure Tax and the Scottish Building Safety Levy.
As all these taxes are relatively modern and use Revenue Scotland’s Scottish Electronic Tax System (SETS) for return submission, it perhaps makes sense that a modern communication system is also implemented. The proposal suggests that communications could be via SETS, email, text or other secure messaging system.
There would be the opportunity for taxpayers to opt out of ‘digital by default’ if digitally excluded or if they do not wish to receive electronic communications. These taxpayers would still have the option to receive communications by ordinary post.
ATT's response supported the initiative in principle but highlighted the following:
- the need for clear legal rules on when communications are sent, delivered and received
- strong safeguards needed to address phishing, spoofing and unauthorised access
- systems should ensure that agents have full visibility and access to communications on behalf of clients
- digital systems should enable taxpayers and their agents to respond, seek clarification and resolve issues efficiently
- non-digital channels must remain available, with simple opt-out processes for digitally excluded users
- phased implementation is recommended
- collaboration with professional bodies and learning from HMRC's programme would help ensure consistent, practical design.
While acknowledging the long-term efficiency gains of digital communications the response emphasises that these must not come at the expense of fairness, reliability, security or usability.