Last week I read an HMRC public document on a proposed change of process for submitting EU trade statistics; a process that involves submitting an "intrastat". This document deals with a change that is to be introduced in April 2012. From then the current two modes of submission will be whittled down to one. Currently you can file electronically or on paper. From April, only the electronic mode will be available.
HMRC is required to review the impact of such a change both on themselves and on business. The idea is to ensure that any policy change that brings anticipated benefits for HMRC does not create disprortionate costs for business. This, in itself, is good practice.
The impact assessment for the change in intrastat submission could be expected to show savings for HMRC, and unsurprisingly it does. The issue would be the costs for business that might offset those savings. But we are told instead that it will save business an estimated £273k per year.
That sounds great, but there is something very strange about it. This change merely withdraws an already existing choice. It does not create any new way of doing it. The only remaining way to do it will be the same one that can currently be used (and which 80% do use). So, telling us that the change will save businesses money rings hollow. If they could save money, or wanted to, they have the ability already, by changing to the electronic alternative. Why then should HMRC present it as something that helps business? What they seem to be saying is that they know better for business than business does for itself. Without any caveat, any varnish, or any sense of irony, they tell business that being forced to submit electronically rather than having the choice over the matter is better for them.
Is a civil servant really in a position to do that? Surely not.
They would say they are told to calculate savings and costs, and that facts are facts. They are not paid to gloss them with subtle explanations or save the blushes of business. But even if they had said that they believed the 80% take up, to date, of the electronic approach had to imply that that was generally the more efficient mode, so businesses would not experience extra costs after meeting those of conversion (which are estimated at £77k), that would have struck the right chord. But they just decided to present the view as though they were the old fashioned "men from the ministry", or as we would now characterise it, nannies from the Nanny State.
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