HM Revenue & Customs. Management of Tax Debt

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1 HM Reveue & Customs Maagemet of Tax Debt REPORT BY THE COMPTROLLER AND AUDITOR GENERAL HC 1152 Sessio November 2008

2 The Natioal Audit Office scrutiises public spedig o behalf of Parliamet. The Comptroller ad Auditor Geeral, Tim Burr, is a Officer of the House of Commos. He is the head of the Natioal Audit Office which employs some 850 staff. He ad the Natioal Audit Office are totally idepedet of Govermet. He certifies the accouts of all Govermet departmets ad a wide rage of other public sector bodies; ad he has statutory authority to report to Parliamet o the ecoomy, efficiecy ad effectiveess with which departmets ad other bodies have used their resources. Our work saves the taxpayer millios of pouds every year: at least 9 for every 1 spet ruig the Office.

3 HM Reveue & Customs Maagemet of Tax Debt LONDON: The Statioery Office Ordered by the House of Commos to be prited o 17 November 2008 REPORT BY THE COMPTROLLER AND AUDITOR GENERAL HC 1152 Sessio November 2008

4 This report has bee prepared uder Sectio 6 of the Natioal Audit Act 1983 for presetatio to the House of Commos i accordace with Sectio 9 of the Act. Tim Burr Comptroller ad Auditor Geeral Natioal Audit Office 14 November 2008 The Natioal Audit Office study team cosisted of: Lee-Ae Murray, Emma Taylor Heather Thompso, Be Gatherer, Chris Hederso ad Vicky Gilso, uder the directio of Jae Wheeler This report ca be foud o the Natioal Audit Office web site at For further iformatio about the Natioal Audit Office please cotact: Natioal Audit Office Press Office Buckigham Palace Road Victoria Lodo SW1W 9SP Tel: Natioal Audit Office 2008

5 cotets summary 4 Part ONE Overall performace i maagig debt 8 Part TWO Maagig ad prioritisig debt 14 Part THREE The costs ad effectiveess of debt 17 collectio methods Part four Prevetig debt arisig 22 Appedices 1 Progress agaist previous Committee 27 of Public Accouts Recommedatios 2 Scope ad Methodology 30 Photograph courtesy of Alamy.com

6 SuMMARy 1 HM Reveue & Customs (the Departmet) collected aroud 450 billio i tax ad Natioal Isurace cotributios from some 35 millio taxpayers i Although most tax paymets are made o time, aroud oe third are ot. The level of debt fluctuates o a daily basis. The total level of debt i the Departmet s Accouts at the ed of was 25 billio. The level of debt recorded o the Departmet s debt maagemet systems i March 2008 was 21.5 billio. The differece is maily because these systems exclude some debt that is due but is paid almost immediately ad there are timig differeces i whe debt is dowloaded from the mai tax systems. I this report we aalyse treds i debt levels usig figures from the debt maagemet systems. 2 Of the 21.5 billio, 17.3 billio was outstadig tax, iterest ad pealties (3.8 per cet of total tax receipts) ad the remaider was overpaymets of beefits ad tax credits billio was maaged by the Departmet s Debt Maagemet ad Bakig Directorate which spet 204 millio ad employed over 6,200 staff o debt maagemet activities i to collect 63 billio of debt. The remaiig 5.3 billio was debt maaged by other busiess areas i the Departmet. 4 MANAGEMENT OF TAX DEBT

7 summary 3 This report examies: The Departmet s performace i maagig debt (Part 1) How the Departmet maages ad prioritises debts (Part 2) The Departmet s methods for collectig debt (Part 3) How it ecourages taxpayers to pay o time (Part 4) 4 The report examies the Departmet s progress i respose to previous NAO ad Committee of Public Accouts reports o the former Ilad Reveue ad HM Customs & Excise. Appedix 1 summarises progress i implemetig recommedatios. This report covers tax debt owed by busiesses, employers ad idividuals across all taxes. It does ot cover tax credits ad beefits. The C&AG s Report o the Departmet s accouts examies its performace i maagig tax credits. Our methodology is at Appedix 2. Coclusios 5 The Departmet has improved its maagemet of tax debt sice our previous reports, so that tax debt as a proportio of et tax receipts is ow lower o most taxes ad the age of direct tax debt has reduced. The Departmet has ot reduced the total level of debt as it aimed to do ad, over the last year, debt as a proportio of et receipts ad the age of debt has icreased o some taxes. The umber of debts has also icreased over the last year by 22 per cet, from 13 millio to 15.8 millio. While the icreases reflect how debts are recorded ad a overall icrease i the umber of taxpayers ad other treds i cosumer debt, they also reflect a chage i the Departmet s priorities to focus more o higher value debts as it seeks to maage with fewer resources. The Departmet has trialled various iitiatives to help maage the icreasig workload, icludig chages to local debt recovery which are i trai but have yet to take effect. A more effective pealty regime could help prevet debt arisig. The Departmet is curretly cosultig o proposed chages. 6 I , the Departmet s Debt Maagemet directorate collected aroud 310 of debt for every 1 spet, a icrease of 10 per cet from The Departmet has limited iformatio o the relative cost-effectiveess of its activities. The Departmet could improve the cost-effectiveess of its collectio operatios by usig the Telephoe Cetre to collect VAT debt which is maaged through separate systems. Automatically likig together debts owed by idividual taxpayers o differet taxes so they are pursued as a sigle debt would require ivestmet but could save costs i the log ru ad help the Departmet pursue smaller debts which it does ot prioritise at preset. 7 The Departmet s debt:et receipts ratio is at the lower ed of the rage for other tax authorities we cotacted, while debt it writes off as a percetage of total debt was similar or higher. The measures the Departmet uses to moitor its performace iclude some, but ot all of the performace idicators used by other orgaisatios. Its debt maagemet approach does ot yet iclude some features that the Committee of Public Accouts ad we recommeded i 2004 ad which have helped other orgaisatios improve debt maagemet. Such features iclude risk profilig ad customer segmetatio, maagig debt through a sigle IT system, iovative methods for commuicatig with customers ad a more efficiet telephoe cetre operatio. These methods would require fudig to implemet, but could reduce collectio costs ad help the Departmet better maage the growig level of debt as it competes with other orgaisatios i a more difficult ecoomic eviromet. The Departmet has udertake some developmetal work ad cotiues to review the case for deployig additioal resources i these areas but does ot have firm plas for implemetatio as other Departmetal chage programmes have take higher priority withi the resources available. Maagemet of Tax Debt 5

8 summary Recommedatios 8 The Departmet has developmetal work uderway i a umber of areas to improve maagemet of debt, for example developig a risk-based approach to prioritisig debts, measurig the cost-effectiveess of collectio activities, usig staff more flexibly ad itroducig commuicatio by voic ad text. This work takes forward previous recommedatios. The fudig available for debt maagemet projects has restricted the scale ad pace of chages achieved ad plaed. I this cotext we have divided our recommedatios betwee those that ca be implemeted relatively easily ad at low cost ad those that would require greater resources but could brig sigificat beefits i the loger term. Recommedatios that ca be implemeted at lower cost a The Departmet measures the average time take overall to collect debts but ot the percetage of debt by value collected withi 30 or 90 days as other orgaisatios are seekig to do. The Departmet should measure how much debt is collected withi these timeframes to help focus o reducig the legth of time it takes to collect debt (paragraph ). b The Departmet does ot curretly kow how much tax it collects i each debt recovery activity ad so caot reliably measure the cost-effectiveess of differet approaches. The Departmet should measure the cost-effectiveess of differet collectio activities so that it ca maage its resources effectively ad idetify opportuities to improve its processes (paragraph 3.3). c The Departmet has improved leaflets ad website iformatio to help taxpayers uderstad their paymet obligatios but some iformatio is limited or ot available. The Departmet should provide clearer iformatio o its website ad i prited guidace o how to fid details of paymet helplies ad iterest charges, ad the obligatio o taxpayers to submit a tax retur if they are set oe, eve if they have o tax to pay. It should also provide clearer iformatio o how a idividual s tax has bee calculated (Figure 10, paragraph 4.4). Recommedatios requirig greater resources d The Departmet geerally prioritises pursuit of debt accordig to value rather tha the likely risks of o-collectio. The umber of debts the Departmet has to maage is icreasig so smaller debts are agig ad will become more difficult ad expesive to collect. The Departmet should use iformatio it holds o customer behaviour, with iformatio from exteral sources, to build up risk profiles for each customer to prioritise ad tailor debt collectio actio ad egotiate paymet arragemets. I the iterim, the Departmet should look to prevet the build up of smaller debts ad achieve more equitable treatmet of taxpayers, thereby reducig the risk that compliace levels could fall if the public perceives that the Departmet is ot actively pursuig certai debts (paragraphs , ). e The Departmet maages direct ad idirect tax debts o separate IT systems. It caot automatically lik the debts a taxpayer has o differet taxes ad pursue all debts at the same time ad it has difficulty comparig performace across taxes. Nor ca it curretly use the automated Telephoe Cetre for collectig VAT debts although a pilot to explore this is plaed for late The Departmet had a pla to itroduce a sigle IT system but had to defer implemetatio because of other fudig priorities. The Departmet should aim to itroduce a system that allows it to pursue debts more efficietly, to maage debts by customer so that debts o differet taxes are liked ad to compare performace across taxes. These chages could either be made progressively or through oe ew system (paragraphs ). f The Telephoe Cetre operatig system does ot allow automated switchig betwee iboud ad outboud calls ad so caot automatically respod to chagig volumes of iboud calls throughout the day. To address this, the Departmet has cosidered various optios for maagig iboud ad outboud calls differetly but its plas are ot yet firm. The Departmet should look to itroduce ew techology to allow greater flexibility i maagig workload, icrease debt collected ad eable staff savigs (paragraph 3.10). 6 Maagemet of Tax Debt

9 summary g Although the Departmet s Telephoe Cetre is ope betwee 8am ad 8pm Moday to Friday ad for some hours at the weeked, staff work maily betwee 9am ad 5pm ad weeked workig is limited. Local recovery officers make most visits durig office hours. The Departmet s research ad evidece from other orgaisatios idicates that the Departmet could collect debt more quickly by extedig Telephoe Cetre opeig hours ad visitig more debtors outside office hours to improve cotact rates. Although some dowtime is ecessary to update IT systems with ew debt iformatio, the Departmet should look to expad debt collectio work i the eveigs ad weekeds ad examie the associated costs ad cotractual issues ivolved (paragraphs 3.10 ad ). h Overseas tax admiistratios we visited have successfully used differet eforcemet powers ad methods for recoverig debt. The Departmet should explore the beefits ad risks of obtaiig a power to recover tax debts from taxpayers salaries or bak accouts without a court order, ad usig private debt collectio agecies to recover some types of debts. Chages i powers would require chages i legislatio to itroduce (paragraphs ). i The Departmet curretly writes to customers to remid them that paymet is due although it is pilotig alterative commuicatio methods. It should itroduce ew methods of commuicatig with customers such as text, or automated telephoe messagig i lie with good practice by other orgaisatios to reduce the amout of debt arisig (paragraph 4.5). j I respose to previous recommedatios, the Departmet has itroduced further paymet optios, icludig paymet by credit card ad direct debit for payig i istalmets. However, techology ad practices of other orgaisatios cotiue to advace. The Departmet should explore the costs ad beefits of icreasig the rage of paymet optios such as itroducig autopaymet by telephoe with the aim of makig payig tax quicker ad more coveiet for differet customer groups (paragraphs ). Maagemet of Tax Debt 7

10 Part Oe Overall performace i maagig debt This part examies good practice i measurig performace i maagig debt ad the Departmet s performace i maagig the level ad age of debt. 1.1 I the Departmet collected 451 billio i tax ad Natioal Isurace cotributios from some 35 millio taxpayers ragig from idividuals to large multi-atioal corporatios. 1 Most idividual taxpayers pay Icome Tax through PAYE ad ay uderpaymets are collected by adjustig their PAYE code. Most debts occur whe paymets of self-assessed Icome Tax, Natioal Isurace cotributios, Corporatio Tax, VAT or employers PAYE are ot made o time. I , aroud 30 per cet of taxpayers with a tax liability did ot pay o time although ofte paymets are made soo after they are due ad therefore do ot require ay actio. Our research estimated that i April 2008 betwee 830,000 ad 1.5 millio (2.2 to 4 per cet) of workig age adults, icludig those who pay their Icome Tax through PAYE, had a persoal or busiess tax debt with the Departmet We last reported o debt maagemet by the Ilad Reveue i 2004 ad by HM Customs & Excise 3 i Followig the creatio of HM Reveue & Customs i 2005, a ew Debt Maagemet ad Bakig directorate was set up. I it spet 204 millio ad employed over 6,200 full time equivalet staff o debt maagemet activities to collect 63 billio of debt. As part of the Departmet s drive for efficiecy savigs the Directorate has reduced its staff umbers by 14 per cet sice The Directorate has also bee implemetig a chage project as part of the Departmet s wider Trasformatio Programme. 4 It plas to sped 29 millio up to 2011 to facilitate flexible methods of paymet ad streamlie processes. It expects to achieve staff savigs of 217 millio by The Departmet has made some progress i implemetig the Committee of Public Accouts previous recommedatios icludig usig more iformatio to trace debtors, improvig iformatio for those i debt ad itroducig paymet by credit card ad direct debit. O others, it has developmetal work uderway icludig prioritisig debts accordig to risk, pursuig more debts through the Telephoe Cetre ad measurig the debt collected withi 30 or 90 days. It is also cosultig o possible chages i legislatio such as seekig additioal powers for eforcig debts ad chagig the pealties it ca impose for late paymet. Full details of the Departmet s progress agaist previous recommedatios are at Appedix 1. The process for collectig ad recoverig debts 1.3 The Departmet has a stadard debt collectio process (Figure 1) supported by a IT system which automatically routes all direct tax debts through the process. The IT system does ot deal with idirect taxes. For most taxes, the Departmet seds out iitial postal remiders requestig paymet oce it becomes due. Debts which are ot paid are referred to the Departmet s Telephoe Cetre which attempts to cotact debtors to obtai paymet, ad the trasfers uresolved debts to local Debt Pursuit Offices. Some debts are trasferred directly to Debt Pursuit Offices. Where a address is icorrect, the Departmet s Tracig Uit traces up-to date cotact details ad missig telephoe umbers are traced by a exteral provider. We cover the operatio of Departmet s collectio activities i Part 3. 1 HM Reveue & Customs receipts, reported by the Departmet as Natioal Statistics. This figure differs from the receipts figure reported i HM Reveue & Customs Accouts for ( 457 billio) which is reported o a accruals basis. 2 Ipsos MORI Omibus Survey, April 2008 face-to-face survey of 1409 adults, weighted to be atioally represetative of the UK workig age populatio. 3 The recovery of Debt by the Ilad Reveue, HC 363, ; Comptroller ad Auditor Geeral s Stadard report o the Accouts of HM Customs & Excise , HC 447, The Comptroller ad Auditor Geeral examied the programme i HM Reveue & Custom s Trasformatio Programme, HC Maagemet of Tax Debt

11 part oe Measurig performace i maagig debt 1.4 Our previous report recommeded improvemets i the Departmet s maagemet iformatio to achieve better performace. The Committee of Public Accouts recommeded that the Departmet should seek to achieve similar clearace rates to the utilities sector, which cleared 90 per cet of debt withi 90 days, to prevet the build-up of older debt ad associated write-offs ad moitor the percetage of debt collected withi 30 ad 90 days i lie with good practice. 1.5 The Departmet is lookig to develop a measure of how much debt, by value, it collects withi 30 days. It does measure the average time take to collect all debt (17.5 days), icludig those debts which are collected quickly followig remider letters. Debts that require itervetio by the Debt Maagemet ad Bakig directorate take loger to collect (72.2 days). 1.6 Debt collectio operatios i fiacial services ad utilities curretly use busiess-wide ad idividual customer data ad various idicators to moitor performace (Figure 2 overleaf). The Departmet measures performace agaist some but ot all of these idicators. 1 The Departmet s approach to collectig debt ad the value of debt at each stage i March 2008 Paymets become overdue Debt maaged by other offices outside the Debt Maagemet directorate ( 3.3 billio) Outstadig Icome Tax, Corporatio Tax ad PAYE debts are dowloaded ito Itegrated Debt Maagemet System ad VAT debts are separately dowloaded ito the Departmetal Trader Register to geerate lists of items for actio Debt Maagemet ad Bakig automatically issues remiders ( 3.2 b) (This figure also icludes auto-remiders issued by tax busiess areas) Self assessed Icome Tax, PAYE, tax credit overpaymets ad some other debts are passed to the Telephoe Cetre where operators cotact the taxpayer to seek paymet 2.3 billio of debt Cases ot settled by the Telephoe Cetre are passed to the Debt Pursuit Offices for eforcemet actio Whe remiders o VAT ad Corporatio Tax cases are usuccessful, the case is trasferred directly to Debt Pursuit Offices 6.3 billio of debt Ucollectible debt is writte-off Debts with ukow addresses passed to the Tracig Uit Whe eforcemet actio is usuccessful, cases are passed to the Eforcemet ad Isolvecy Service for bakruptcy or widig up procedures 2.3 billio of debt Debts with ukow telephoe umbers passed to exteral tracig service provider Court proceedigs Source: Natioal Audit Office NOTE Figures exclude suspeded debt ( 0.4 billio maaged by the Debt Maagemet ad Bakig Directorate ad 2.0 billio maaged by other offices) ad debt i specialist collectio offices, such as the Couty Court Uit ad New Busiess Uit ( 1.7b). Figures iclude tax credit debt. Maagemet of Tax Debt 9

12 part oe 1.7 We have used the data curretly held by the Departmet to measure curret performace ad treds over time i the total levels of tax debt ad o differet taxes, levels of debt writte off ad the age profile of debt. Where possible we make comparisos with other orgaisatios. We look at costs of collectio i Part 3. Levels of debt 1.8 The debt balace fluctuates o a daily basis as debts are paid ad ew debts arise. We have aalysed treds i debt levels i recet years by comparig the level of debt recorded i the Departmet s Debt Aalysis Matrix i March with the aual et receipts for each tax. We used the Debt Aalysis Matrix because it is the maagemet iformatio system used by the Departmet to operatioally maage ad regularly report to seior maagemet o its debt levels. The figures i the Matrix i March 2008 were 3.5 billio lower tha the figures reported i the Departmet s Accouts as at 31 March The mai reasos are that the Matrix excludes some debts which were due but which were paid almost immediately ad that there are timig differeces i whe the debt is dowloaded to the Matrix from the mai tax systems. The majority of the differece related to VAT debt ( 2.5 billio) which was due but which had ot yet dowloaded oto the debt maagemet system. 2 Key Performace Idicators used by the Departmet ad other orgaisatios KPIs used by a rage of other orgaisatios What the Departmet measures Collectio performace Debtor days = debt balace/receipts x 365 or Debtor days = debt balace/debt raised x 365. Measures the umber of days worth of debt outstadig. Aged debt profile the older the debt, the slower debt is beig collected. Collectio efficiecy: debt collected/full time equivalet staff. The Departmet measures debtor days usig both methods. The Departmet ca measure tax debt that is more tha 3 moths, 6 moths ad 1 year old ad for direct taxes, debts more tha 2 years ad more tha 4 years old. The Departmet measures debt collected/full time equivalet staff. Cost performace Yield-cost ratio by collectio activity to moitor the cost effectiveess of differet collectio actios e.g. telephoe cetre. Average cost of collectio per debtor measure of the cost effectiveess of the collectio process. The Departmet measures the amout of debt collected per 1 spet. It measures cost of collectio per debt collected by activity ad has work uderway to measure the amout of debt collected per 1 spet by collectio activity. Not measured by the Departmet. Compliace performace Deliquecy ratio: umber of deliquet debtors/umber of active debtors. Proportio of debtors who have missed several paymets. Bad debt loss ratio: ucollectible debt/total debt to moitor the proportio of ucollectible debt ad possible future write-offs. 1 Not measured by the Departmet. The Departmet measures the amout of debt it writes off. 1 Source: Natioal Audit Office NOTE 1 Write-offs are debts that are cosidered to be irrecoverable because i practice the Departmet caot collect them. It also measures remissios which are debts capable of recovery but the Departmet has decided ot to pursue the liability, for example, o the grouds of value for moey or official error. 10 Maagemet of Tax Debt

13 part oe 1.9 I March 2008, the tax debt balace was 17.3 billio o the Matrix ad comprised outstadig tax, iterest ad pealties for late filig ad icorrect tax returs. I additio to tax debt, the Departmet was owed 4.2 billio arisig from overpaymets of tax credits. We have ot covered tax credit debt i this report ad have excluded tax credit debt from the data where possible. We examie maagemet of tax credits separately i the C&AG s Report o HMRC s Accouts each year. The Debt Maagemet ad Bakig directorate set a target to reduce total debt outstadig by 20 per cet from 20.4 billio i 2006 to 16.6 billio by March I practice the amout icreased to 21.5 billio at March 2008, maily because tax credit debt icreased by 57 per cet over the period ad Corporatio Tax debt by 37 per cet. Of the 21.5 billio, 16.2 billio was maaged by the Debt Maagemet ad Bakig Directorate ad the remaiig 5.3 billio was maaged by other busiess areas i the Departmet The mai areas of debt are PAYE (32 per cet of total tax debt o average durig ), VAT (27 per cet) ad self-assessed Icome Tax (21 per cet) (Figure 3). The level of debt fluctuates throughout the year from 15.6 billio to 18.3 billio, risig after the differet deadlies for payig each tax. For example, self-assessed Icome Tax debt rises after paymet deadlies at 31 Jauary ad 31 July ad a peak i PAYE debt follows the ed-of-year deadlie i May The debt figures exclude stoodover tax, estimated at aroud 15 billio, which comprises direct tax assessmets (for example o Corporatio Tax ad self assessed Icome Tax) which are ot payable while uder appeal. The Departmet caot legally collect stoodover tax ad so does ot classify it as debt. The Departmet icludes suspeded tax i its debt figures. Estimated at aroud 2.4 billio, it arises whe assessmets of idirect taxes (for example VAT) are ot yet cofirmed. It icludes upaid tax of 1 billio relatig to Missig Trader fraud ivestigatios. Missig Trader fraud is a type of VAT fraud, which i its simplest form ivolves a busiess obtaiig a VAT registratio umber i the UK for the purposes of purchasig goods free from VAT i aother EU member state. The busiess sells the goods at a VAT iclusive purchase price i the UK ad the goes missig or defaults without payig the output tax due to the Departmet. 5 The amouts are legally collectible ad classed as debts, but because of their ature they may ot be recovered so we have excluded or show these amouts separately i some areas of our aalysis The level of tax debt as a proportio of et tax receipts icreased from 3.8 per cet i to 4.3 per cet i ad fell to 3.8 per cet i (Figure 4 overleaf). The percetage level of Icome Tax-related debt (which icludes self assessed Icome Tax, PAYE, Natioal Isurace cotributios ad Capital Gais Tax) is lower tha i whe we reported previously. This debt rose sharply i , largely because of PAYE debt, ad the fell agai as the Departmet prioritised this area. Corporatio Tax debt is also lower tha whe we previously reported. It fell to 4 per cet i Sice the it has icreased as the umbers of icorporated busiesses ad so Corporatio Tax debts icreased. VAT debt as a proportio of VAT receipts has rise to 5.1 per cet, partly because of Missig Trader debt which is suspeded whilst uder ivestigatio. Excludig suspeded debt, the icrease is from 1.3 per cet i to 2.5 per cet i Corporatio Tax 10% Self-assessed Icome tax 21% Proportio of debt by tax average for Other taxes 10% VAT 27% PAYE 32% Source: Natioal Audit Office aalysis of HM Reveue & Customs tax data 5 Comptroller ad Auditor Geeral s Stadard Report o the Accouts of HM Reveue & Customs , HC 626, Maagemet of Tax Debt 11

14 part oe 1.13 The Departmet writes off debt which i practice it is uable to collect, maily where taxpayers have become isolvet ad so further pursuit is preveted by statute. I , the Departmet wrote off 5.6 billio i tax debt, 1.2 per cet of et tax receipts (Figure 5), compared to 3.1 billio or 0.7 per cet of et receipts i Most of the debt writte off i was VAT ( 3.6 billio), much of which was associated with Missig Trader fraud I other coutries we visited, tax debt as a percetage of et receipts raged from 2.7 to 12 per cet (Figure 6). The Departmet s tax debt as a percetage of receipts is at the lower ed of this rage (3.4 per cet to 4 per cet throughout the year). Overall, the Departmet s level of debt writte off as a percetage of total debt was similar to or higher tha i the coutries we visited. Age of debt 1.15 Commercial orgaisatios fid that, i a competitive eviromet, it is importat to collect debt as quickly as possible sice older debt is more difficult ad more expesive to collect. Sice 2007, geeral ecoomic chages i the UK have led to fluctuatios i iterest rates ad a reductio i available credit. Leders are icreasigly focussed o collectig debts withi the first 90 days followig chages to the bakig rules o providig for debt. 6 Much of the debt the Departmet pursues, for example paymets of self-assessed Icome Tax ad Corporatio Tax are due some time after the profits/icome to which they relate. 4 Tax debt as a percetage of et tax receipts Percetage Icome Tax Corporatio Tax VAT VAT excludig suspeded VAT Total Positio previously reported by Natioal Audit Office 10.6% % % % Source: Natioal Audit Office aalysis of HM Reveue & Customs tax data NOTES Comparable tax debt figures from the Departmet s Debt Aalysis Matrix report are available from owards oly. Icome Tax figures iclude self-assessed Icome Tax, PAYE, Natioal Isurace cotributios ad Capital Gais Tax. For referece, Figure 4 also shows debt figures previously reported by the NAO i the Stadard Report o the Accouts of HM Customs & Excise, HC 447, ( VAT figures) ad The Recovery of Debt by the Ilad Reveue, HC 363, ( Icome Tax ad Corporatio Tax figures). These figures were produced usig Maagemet Iformatio systems i operatio before the merger of the two departmets, ad therefore are ot directly comparable. Net receipt figures are HMRC s aual receipts reported by the Departmet as Natioal Statistics. For ad et receipt figures are from HM Customs & Excise ad Ilad Reveue Trust Statemet Accouts for ad respectively. 6 The Basel II Accord created iteratioal stadards i bakig laws ad regulatios which are used by bakig regulators to determie how much capital baks eed to put aside to guard agaist fiacial ad operatioal risks. As part of the Accord, debts older tha 90 days attract a higher risk ratig ad therefore require more capital to be put aside. 12 Maagemet of Tax Debt

15 part oe 1.16 Nearly a third ( 4.5 billio) of the Departmet s tax debt (excludig suspeded VAT) is greater tha oe year old. Sice we last reported o the Ilad Reveue the age profile of direct tax debt has improved. 26 per cet of debt was more tha oe year old i March 2008 compared to 37 per cet i March The biggest reductio was i PAYE debt over oe year old, from 43 per cet to 18 per cet, as the Departmet prioritised this type of debt. The amout of self-assessed Icome Tax debt greater tha oe year old icreased from 38 per cet to 41 per cet. VAT debt over oe year old has rise sice late 2007 as more Missig Trader debts become collectible followig ivestigatio At March 2008, ie per cet ( 1.1 billio) of direct tax debt was betwee two ad four years old, ad a further six per cet ( 784 millio) was over four years old. Most debt over two years old was self-assessed Icome Tax debt. Levels of older Corporatio Tax ad PAYE debt have remaied steady or reduced slightly sice April At August 2008, 18 per cet ( 777 millio) of VAT debt was more tha two years old, of which 36 per cet ( 279 millio) was suspeded debt. 5 Writte off debt as a percetage of et tax receipts Percetage Icome Tax Value Added Tax Corporatio Tax Total Source: Natioal Audit Office aalysis of HM Reveue & Customs tax data 6 Total debt as a percetage of et receipts Overseas tax admiistratio Receipts (2007) (billios) Total debt (2007) (billios) Debt as a percetage of receipts (%) Caada ($CA) Netherlads ( ) Republic of Irelad ( ) Uited Kigdom ( ) USA ($) 2, Source: Natioal Audit Office aalysis of data provided by overseas tax admiistratios NOTE These figures give a idicatio of the rage of debt as a percetage of et receipts. It is difficult to directly compare each tax admiistratio because of differeces i the types of tax ad the way i which tax is collected, differet regulatios ad powers, for example o eforcemet ad write-offs ad levels of tax debt will vary throughout the year. Maagemet of Tax Debt 13

16 Part two Maagig ad prioritisig debt This part examies the Departmet s projects such as likig debts across taxes ad risk profilig to better maage ad prioritise icreasig volumes of debt. Number of debts 2.1 The total umber of tax debts has rise by 22 per cet from 13.0 millio i March 2007 to 15.8 millio i March The umber of PAYE debts has more tha doubled, partly because the Departmet is ow recordig o its IT system some debts that were ot previously recorded ad because it is trasferrig some PAYE pealties for late filig oto the system more quickly tha it did previously. I 2006, the Govermet itroduced a ew Corporatio Tax bad which led to a icrease i Corporatio Tax liabilities ad cosequetly, Corporatio Tax debts have rise by over 50 per cet. The umber of VAT debts has rise by 37 per cet ad self assessed Icome Tax debts have rise by six per cet. I particular, the umber of lower value debts has icreased. For example, a exercise by the Departmet showed that betwee April 2006 ad September 2007 debts betwee 500 ad 999 icreased by 40 per cet ad debts betwee 1,000 ad 4,999 icreased by 25 per cet. 2.2 There are a umber of possible reasos for the icrease i umbers of tax debts. It ca be oly partly explaied by a icrease i the tax base. Betwee ad the umber of Icome Tax taxpayers icreased by oe per cet ad registered traders by four per cet. More widely, cosumer debt has doubled over the last seve years. Some debtor groups may have become more kowledgeable about recovery processes. Coicidig with the rise i its workload, the Departmet s debt maagemet staff has reduced by 14 per cet sice April 2006, as part of the Departmet s overall staff reductios to reduce headcout by 12,500 by The Departmet s prioritisatio of higher value debts sice August 2007 (see below) is also likely to have cotributed to the rise i umbers of debts. How the Departmet prioritises collectio of debt 2.3 The debts the Departmet maages rage widely i value. Figure 7 shows that higher value debts represet a low percetage of the umber of debts but a high proportio of the value. The Departmet prioritises higher value debts, ad the PAYE debt, to maage its workload. 7 The umber of direct tax debts1 i each value category at 31 March 2008 Amout ( ) ,000-4,999 5,000-19,999 20,000-99, ,000+ Percetage of debts i each category Percetage of debts by value i each category Source: Natioal Audit Office aalysis of HMRC data NOTE 1 Data icludes PAYE, Corporatio Tax ad self-assessed Icome Tax debts. The Departmet does ot have the percetage of debts by value for VAT. 14 Maagemet of Tax Debt

17 part two The Departmet has prioritised debts by value sice August 2007 to help it maage icreasig debt with fewer resources, ad help maitai cashflow to the Exchequer. Previously, the Departmet prioritised highest value ad most recet debt. Automated remider letters are issued for all debts, irrespective of value. 2.4 Prioritisig collectio of debt by value maximises tax collected i the short term. Other orgaisatios such as the Caadia tax authority also prioritise debts by value but combie it with other methods of prioritisatio, icludig age, risk of default ad customer type. 2.5 I focusig o higher value debts, there is a risk that actio take agaist some taxpayers will be limited to automated remider letters ad that if taxpayers are ot treated equitably, compliace i payig o time will fall if the public perceive that the Departmet pursues some debts more rigorously tha others. The experiece of the Departmet, ad other orgaisatios that collect debt, suggests that older debts are harder ad more expesive to collect. To deal with its high caseload, the Departmet established a separate uit for small debts ad is takig steps to lik debts across taxes ad idetify higher risk debts. We examie these approaches i more detail below. Likig debts across taxes 2.6 We previously recommeded 7 that the Departmet should where appropriate pursue all debts owed o differet taxes durig iitial cotact with the debtor. The Departmet does ot i most cases lik all of a debtor s liabilities or idetify where taxpayers with debts are owed refuds across differet taxes because of limitatios i its IT systems. The Departmet does however lik ad maage joitly high value debts, debts uder Time to Pay ad debts beig submitted for distrait, couty court or civil recovery actio. Large debt collectio operatios i fiacial services, utilities ad overseas tax admiistratios have ivested i databases to eable them to view customers accouts as a whole. The Departmet has examied how to itegrate all taxes oto oe IT system, but has decided it does ot have sufficiet fudig for the project. 2.7 The Departmet caot readily establish how may taxpayers have debts o more tha oe tax. I a trial i early 2008, the Departmet examied more tha 2,000 VAT cases to see if they had debts o other taxes. Twety seve per cet of the cases, totallig 9.2 millio, also had direct tax debts, maily o PAYE. 2.8 Maagig each debt separately icreases the cost of collectio because of multiple cotacts with the taxpayer ad makes it more difficult to prioritise debts. Some debts are idividually of low value, but whe added to the taxpayer s other debts could become a higher priority. I the trial, the Departmet foud that 56 per cet of lower value VAT debts could be liked with other debts makig them higher priority ad it pursued 1.1 millio of debt sooer tha it otherwise would have doe. The Departmet estimates it could pursue a additioal 26 millio out of aroud 217 millio of VAT debt if it applied the same approach for all lower value VAT debts. Maagig small debts 2.9 I March 2008, 70 per cet of direct tax debts were less tha 500. I the 2008 trial the Departmet foud that 17 per cet of small debts could be liked. It established the Small Debt Uit followig the trial to review all debts uder 500 to establish whether they ca be liked with debts o other taxes ad pursued more quickly. I October 2008, however, it decided to redeploy the uit s resources to collect a wider rage of debts I some circumstaces legislatio allows the Departmet to adjust a taxpayer s tax code to collect certai self assessed Icome Tax ad tax credit debts through PAYE. A exercise by the Departmet estimated that some 540,000 cases, totallig almost 97 millio could be collected i this way. While some small debts are already collected i this way, the Departmet could make greater use of this approach. It plas to coduct small scale trials i to better uderstad both the customer reactio ad the costs of doig so. Taxpayer groups we cosulted suggested that, i collectig debts via the tax code, the Departmet should clearly explai how the debt has bee calculated ad provide the opportuity to appeal agaist adjustig the tax code as a method of recovery. 7 The recovery of Debt by the Ilad Reveue, HC 363, Maagemet of Tax Debt 15

18 part two Risk profilig of debts 2.11 The Committee of Public Accouts ad we previously recommeded that the Departmet adopt good practice used by other orgaisatios by developig scorig techiques to categorise taxpayers by risk. Risk scorig combies iteral ad exteral data such as socioecoomic data ad Credit Referece Agecy data to gai a isight ito the customer s behaviour ad level of idebtedess with other leders ad assig a score to debtors. The risk score ca be used to group customers with similar characteristics ad behaviours ad idetify the most appropriate collectio strategy for each customer groupig. Risk profilig also helps orgaisatios improve their uderstadig of customer behaviour ad improve future compliace. Risk scorig debtors allows orgaisatios to better support those who do ot uderstad their obligatios or are i fiacial crisis, while dealig promptly with debtors who deliberately pay late. Orgaisatios ca also idetify the total debt at risk because of isolvecy or likelihood of default. Box 1 describes the Netherlads tax authority s approach to risk scorig I September 2007, the Departmet bega a study for idetifyig higher risk, lower value debts. I the absece of fudig for fully automated risk profilig, it aims to make better use of staff kowledge ad its existig iteral ad exteral data sources, such as credit referece data, to develop more itelliget, targeted ad tailored itervetios for those idividual debtors who ca pay. It has coducted a separate risk modellig exercise to idetify ad rak VAT debtors who are more likely to pay, maily usig iteral data but has ot yet started approachig these debtors differetly The Departmet has tailored its approach o differet groups of debtors based o risk as part of other iitiatives. For example the Departmet foud that some types of debtor paid reasoably quickly after receivig the first demad ad it has used this iformatio to delay further recovery actio i such cases so as to deploy resources more effectively Other orgaisatios have sigificatly improved their performace through risk profilig. For example, a eergy supplier we spoke to used customer-level data to produce scorig models, segmeted customers ito groups ad tested alterative strategies o differet groups. They reported reductios i total debt of eight per cet ad debt greater tha six moths old of 28 per cet. Similarly, a debt collectio agecy reported improvemets ragig from 15 to 40 per cet i the amout collected for differet debtor groups followig the itroductio of risk scorig Risk profilig would also allow the Departmet to idetify more vulerable taxpayers. For example, the Departmet could tailor its iitial correspodece to the eeds of particular taxpayers ad could cotact taxpayers with relatively small debts but who would eed support i payig ad discuss paymet optios at a early stage. This could avoid smaller debts buildig up to sums that the taxpayer would have o hope of payig. BOX 1 Netherlads Tax Admiistratio s approach to risk modellig The Netherlads curretly has a two-track debt collectio approach. Taxpayers with a previous history of o-compliace are idetified ad fast-tracked through the system. They pla to itroduce a more developed risk processig system durig 2009: Step 1: Each taxpayer is assiged poits accordig to kow criteria, evets, behaviours ad previous compliace record e.g. the umber of times the taxpayer s direct debit bouced, the umber of times the taxpayer has bee issued paymet remiders, summos or distrait warrats, the umber of times the tax admiistratio has levied o goods or the umber of times the taxpayer applied for a paymet arragemet or waiver. Step 2: The poits are cosolidated to calculate a credit ratig for each customer so that the more compliat the taxpayer, the higher the credit ratig. The ratig ca chage over time accordig to behaviours ad evets. Step 3: The credit ratig determies the collectio treatmet. The Netherlads pla to have up to five collectio tracks. For example, remiders could be issued to taxpayers with high credit ratigs. More robust eforcemet actio such as levyig o goods, or eforced direct debit could be used immediately agaist less compliat taxpayers. Step 4: Moitor the impact o debt recovery performace over time so that it could fie-tue the system by varyig either the scorig or the respose. 16 Maagemet of Tax Debt

19 Part three The costs ad effectiveess of debt collectio methods This part examies the cost-effectiveess of the tracig uit, the Debt Maagemet Telephoe Cetre, the local Debt Pursuit Offices ad the Eforcemet ad Isolvecy Uit. It also draws o practice i the private sector ad overseas tax authorities. Measurig the effectiveess of differet collectio activities 3.1 Our previous report 8 cocluded that the Departmet required better iformatio o the amout of debt collected ad the average uit cost for differet methods of collectio to allow the Departmet to aalyse its success ad use resources cost-effectively. Although the Departmet ca measure the total debt collected for every 1 spet it caot yet measure the debt collected from all of its separate activities. Although some private sector orgaisatios are able to measure activity costs, most orgaisatios cosulted were, like the Departmet, i the process of researchig ad itroducig activity based costig. 3.2 Followig staffig reductios as part of the Departmet s drive for efficiecy savigs, Debt Maagemet directorate staff costs of debt collectio fell from millio i to 170 millio i The directorate collected 310 of debt for every 1 spet i , a icrease from 281 i I 2008, the Departmet started work to develop activity-based costig although it has ot yet set a firm timetable. Ahead of results from this work, the Departmet provided summary data from which we have bee able to estimate some idicative costs per debt actioed for the mai high level collectio activities (Figure 8). The cost of actioig debts by the Telephoe Cetre is lower because it is desiged to process quickly high volumes of simpler debts. Recovery offices ad the Eforcemet ad Isolvecy Uit icur higher costs because the debts are more complex. Debts may be subject to oe or more itervetios before they are collected. 8 Cost of differet collectio activities Mai collectio activity umber of debts Cost of activity Cost per debt Cost per debt actioed 1 (000s) ( m) actioed ( ) actioed ( ) Telephoe Cetre 3, Debt Pursuit Offices 8, Eforcemet ad Isolvecy Overall 11, Source: Natioal Audit Office aalysis of HMRC data NOTES 1 Actioed meas that the debt has either bee paid i full or time to pay arragemets have bee agreed, or it has moved to aother stage i the recovery process or the Departmet has established that there is i fact o debt to pay. The Departmet does ot have iformatio o the umber or amout of debt actually collected by each collectio activity. 2 Both the umber of debts actioed ad the cost iclude tax credit overpaymets. It was ot possible to exclude these amouts. 8 The recommedatios i our previous report, ad i the report by the Committee of Public Accouts The Recovery of Debt by the Ilad Reveue HC 363, , were made for Ilad Reveue. Maagemet of Tax Debt 17

20 part three Tracig debtors addresses ad telephoe umbers 3.4 The Committee of Public Accouts 9 oted that the former Ilad Reveue wrote off 55 millio (at prices) i 2002 because it could ot trace the taxpayer ad that 300 millio of debt over a year old related to cases where the Departmet did ot have up-to-date telephoe umbers ad addresses. The Committee recommeded that the Departmet should make maximum use of other Departmets records to fid taxpayers it caot trace, ad seek a legal power to require taxpayers to provide up to date cotact details. 3.5 While some taxpayers, such as VAT registered traders, are legally required to provide up-to-date cotact details, may are ot. The Departmet has cocluded that it should ot seek additioal legal powers to require all taxpayers to provide up-to-date cotact details because it cosiders the admiistrative burde o taxpayers would be too great ad because the requiremet could be difficult to eforce. It has, however, itroduced measures to improve its tracig of debtors addresses ad telephoe umbers ad ca obtai iformatio from the Departmet for Work ad Pesios, Driver ad Vehicle Licesig Agecy, local authorities ad other third parties. The 2008 Review of Iformatio Security at HM Reveue & Customs 10 suggested however that the Departmet s customers should have greater resposibility for maitaiig their records ad opportuities to maage this themselves, for example, through a olie accout. 3.6 Each year the Departmet refers to its Tracig Uit over 600,000 cases where it does ot have the correct taxpayer address. The Uit uses various iformatio to cofirm taxpayers addresses ad has itroduced ew IT tools ad deployed additioal staff as part of a Sped to Raise iitiative. 3.7 Sice , the Departmet has reduced the total value of cases awaitig tracig by 52 per cet, from 366 millio to 177 millio. I , the Departmet spet 10 millio o tracig. It estimates that it collected 114 millio more debt i 2007 by icreasig tracig activity. The Uit is meetig most of its targets, successfully tracig over 90 per cet of direct tax cases referred to the Uit. It has ot set targets for tracig VAT debtors. The Departmet wrote off over 300 millio i 2007 (Figure 9) because it could ot trace debtors, over three times the amout it wrote off i Of this, 210 millio related to direct taxes. I 2008, the Departmet wrote off 178 millio of idirect taxes, of which 139 millio related to VAT. It attributes the icrease i write-offs sice 2002 to icreased tracig activity ad a greater focus o high value debts, eablig the Departmet to idetify ad write off higher levels of utraceable debt. 3.8 The Departmet does ot have data o how may debtors have a icorrect or missig telephoe umber. Other orgaisatios icludig water compaies ad baks have high umbers of icorrect telephoe umbers: a medium-sized bak said it had iaccurate telephoe umbers o up to 50 per cet of cases. The Departmet has a cotract with a exteral provider to trace missig telephoe umbers. The Departmet does ot kow how much it costs to trace each telephoe umber. The estimated success rate i tracig umbers is aroud 19 per cet although the cotract does ot specify a target. If the exteral provider caot trace a umber, a Debt Pursuit officer visits the taxpayer s home or busiess address to pursue collectio. Usig the Telephoe Cetre to collect debt 3.9 The Committee of Public Accouts ad we previously recommeded that the Ilad Reveue should route all its tax debts through the automated Telephoe Cetre ad that this would be a importat step to esure that the ew HM Reveue & Customs had systems i place for maagig debts efficietly across its customer base. The Departmet s Telephoe Cetre ow deals with all self-assessed Icome Tax debt (except very high value debts) ad all PAYE debt as well as the Costructio Idustry Scheme ad tax credit overpaymets. The Departmet plas to start routig Corporatio Tax 9 Level of write offs because the Departmet could ot trace the debtor ( m) ( m) ( m) ( m) Direct tax write-offs Not yet available Idirect tax write-offs Total write-offs Source: Natioal Audit Office Aalysis of HMRC data NOTE All figures are i real terms. Write off figures based o data at the ed of October for direct taxes ad ed of March for idirect taxes. Direct tax write-offs iclude Natioal Isurace Cotributios for 2006 owards. 9 Committee of Public Accouts 49th Report, The Recovery of Debt by the Ilad Reveue, HC Review of Iformatio Security at HM Reveue & Customs, Kiera Poyter, Jue 2008, paragraph xii Maagemet of Tax Debt

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