ATT responds to consultation on draft legislation: Improving the data HMRC collects from its customers

The ATT has responded to the HMRC discussion document Tax Administration Framework Review: Information and data (‘the Consultation’) which was issued on 14 March 2024.

The Consultation sought views on draft regulations where:

• employers will be required to provide more detailed information on employees’ hours paid via RTI PAYE reporting
• directors in owner-managed businesses will be required to provide the amount of dividend income received from their own companies separately to other dividend income, and the percentage share they hold in their own companies via their Self-Assessment return
• the self-employed will be required to provide information on start and end dates of self-employment via their Self-Assessment return

In the ATT's response, we considered that if the rationale for collecting the ‘employee hours paid’ was to support work undertaken by HMRC on compliance with the National Living Wage (NLW) or National Minimum Wage (NMW), then this wouldn’t work as the NLW/NMW are calculated based on hours ‘worked’. We had several issues with the dividend proposals and consider that it would be much more logical (and more reliable) to obtain this information from Companies House. Finally, we agreed that the start and end dates of self-employment should be made mandatory, but that given the difficulty sometimes in establishing when there is a start or an end date, that clearer guidance in the tax return accompanying notes and on GOV.UK.