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Travel and Subsistence Discussion Paper

Chartered Accountants Ireland

CA House

47–49 Pearse Street

Dublin 2

Private and confidential

HMT Travel and Subsistence Review Team,

Personal tax team,

HM Treasury,

1 Horse Guards Road,

London

SW1A 2HQ

8 December 2015

Dear Sir/Madam,

Travel and subsistence: discussion paper

Introduction

The Northern Ireland Tax Committee of Chartered Accountants Ireland is pleased to have the opportunity to comment on the above consultation document published on 22 September 2015. Information about Chartered Accountants Ireland and the Northern Ireland Tax Committee are provided on the previous page.

We would be happy to discuss any aspect of our comments herein and to take part in any further consultations/initiatives in this area that there may be in the future.

We wish to briefly comment on the current consultation.

Modernisation and simplification

Where the proposals represent modernisation and simplification of the existing rules, we are broadly supportive of the draft framework outlined in the review document and the principles that any new set of rules should try to uphold.

Revenue raising

The government believes that any reform to the current rules should not adversely impact on the exchequer. We note the comment that “small, principled changes to restrict some aspects of tax relief for travel and subsistence expenses will be required in order to balance more generous simplifications”.

Whilst the focus of this review is to modernise and simplify the existing rules, the outcomes reached should not result in revenue raising. Overall, the exchequer position arrived at should be neutral. The initial impact assessment will be critical to ensure this objective is achieved.

Thereafter, we would suggest a further review is undertaken within a two year period of the new rules being introduced to examine whether exchequer neutrality has been achieved and address any unintended consequences post implementation.

Conclusion

Whilst mindful of the consultation deadline, we feel that there are broader issues arising from this review. This particular review has implications not just for taxpayers and private sector employers, but for the UK government as an employer.

Accordingly there may be implications for human resources and other contractual obligations relating to employments generally, which we are not best positioned to comment on because they are not solely tax issues. Any proposals to change the law governing the tax status of travel and subsistence expenses should only be made after examining these issues.

Freedom of Information

We note the scope of the Freedom of Information Act with regards to this submission. We have no difficulty with this response being published or disclosed in accordance with the access to information regimes. This response will be published on our own website and will be available to all of our members and the general public.

Do not hesitate to contact Brian Keegan (brian.keegan@charteredaccountants.ie) or Leontia Doran (leontia.doran@charteredaccountants.ie) of this office should you require anything further.

Yours faithfully,

Paddy Harty

Chairman

Northern Ireland Tax Committee

Chartered Accountants Ireland

Source: Chartered Accountants Ireland. www.charteredaccountants.ie.