Chartered Accountants Ireland has submitted a response to HMRC's consultation paper on working with tax agents. While Chartered Accountants Ireland supports the consultation process as the most appropriate means of discussing the efficient administration of the tax system, we rebut a number of the suggestions put forward in the paper.

In particular, Chartered Accountants Ireland rejects HMRC suggestions that it would either regulate the profession in some shape or form by having a register of tax agents, or engage with the disciplinary processes of professional bodies or directly penalise firms for sloppy work.

The response paper raises the following points:

• Members of Chartered Accountants Ireland are already regulated by an independent body – Chartered Accountants Regulatory Body (CARB). Much of what the HMRC proposes in the form of direct regulation is already provided for and implemented by CARB through practice review and through its rigorous complaints and disciplinary procedures.
• A tax agent registration regime would impose additional compliance costs and would potentially fall foul of the of the European and Competition law consequences of state interference with the market.
• The design principles of the consultation paper do not take account of the many discussions which have already taken place with the Tax Agents and Advisors Steering Group in recent years. The consultation paper also does not appear to take account of the conclusions of the OECD Forum on Tax Administration which was careful not to advocate the creation of a tax agent registration system by Revenue Authorities.

Chartered Accountants Ireland's response paper has been published and is reproduced below at 2.05.