Select Committee on Public Accounts Forty-Eighth Report


2  VAT debt management

18. In 2004-05 HM Customs and Excise collected gross VAT receipts of more than £125 billion. Not all VAT is remitted to the Department by the due date. It notifies in writing traders who fail to pay established liabilities when payment is overdue. At March 2005 overdue VAT recorded on the Departmental Trader Register amounted to £2.6 billion.

19. The overall aims of the Department's debt management activity are to reduce debt outstanding, to maximise revenue collected and to encourage greater future voluntary compliance amongst the whole customer population. Effective debt management also contributes to the delivery of the Department's Public Service Agreement target to reduce VAT losses to no more than 12% by March 2006.

20. In our earlier report on HM Customs and Excise management of VAT debt, we noted that debt rose rapidly in the five-year period to 31 March 2002.[32] The Department attributed this to number of factors, including: a rising tax yield, its efforts to tackle certain types of fraud, and an increase in the proportion of traders challenging its assessments of VAT liabilities. We recommended that the Department should improve its IT systems handling debt management and take action to reverse the rising trend in debt levels.

21. Since 2003, the Department have taken steps to improve debt management. These changes included: the launch of a National Business Model to promote consistency in the management of debt, with a focus on risk and compliance, and training for caseworkers in debt management skills. In 2004-05, as part of a special initiative, HM Treasury provided resources for an additional 150 staff over a two year period to assist in the recovery of an additional £370 million in revenue.[33] The Department is also upgrading the Trader Register to correct missing or de-registered debts, introduce a case tracking system and improve management information.[34]

22. Since the introduction of the strategy in 2003, HMRC have reduced the level of debt available for immediate collection, although the overall level of debt increased (Figure 3). Recoverable debt has decreased from £1,240 million in March 2002 to £913 million in March 2005.Figure 3: Analysis of debt on the Departmental Trader Register
Type of debt
March 2002 (£m)
March 2005 (£m)
Change
+/-
(£m)
Definition
Recoverable Debt
1,240
913
-327
Debt available for recovery action, including by legal process in the Civil Courts.
Suspended Debt:
Under Investigation
216
792
576
Debt assessed where a trader is under Customs Law Enforcement investigation.
Under Appeal
243
426
183
A disputed liability where a trader has appealed to an independent VAT Tribunal or protective assessments pending legal action.
Missing Trader
178
204
26
Debt owed by traders who cannot be traced by the Department.
Disputed liability
51
60
9
A disputed liability where no appeal is in progress.
Time-To-Pay
141
92
-49
An agreement between Customs and the trader to receive money in instalments
Other
-7
67
74
New suspended debt categories
Total suspended
822
1,641
819
TOTAL DEBT
2,062
2,554
492


Source: HM Revenue and Customs

23. The Department is taking the opportunity of the merger of Revenue and Customs to pool its knowledge and create a new debt management organisation which will be capable of benchmarking itself against the best practice.[35]

Suspended debt

24. While the extra resources put into VAT compliance have uncovered fraud and therefore debt, the Department has not always been able to collect this debt. Debt recorded on the Trader Register may be suspended from recovery for a variety of reasons: the trader may be missing, the debt is subject to ongoing criminal investigations; or the Department's assessment may be under dispute by the trader. As Figure 3 shows, between March 2002 and March 2005 suspended debt on the Trader Register increased from £822 million to £1,641 million. The increase is primarily due to the increase in a type of fraud involving traders who go missing.[36]

Level of reported debt

25. The Department has encountered difficulties in managing the IT systems used to support its VAT accounting and collection. The Department's VAT Mainframe accounting system records information on all VAT registered businesses and is updated daily. The Departmental Trader Register is the case handling system for VAT debt management and is updated from the VAT Mainframe three times a month. Not all VAT debt has been transferred onto the Trader Register (Figure 4).

Figure 4: Overview of VAT Debt Accounting System


26. The Department has placed 'inhibitors' on certain debts on the VAT Mainframe to prevent them from being transferred onto the Register. Most of this inhibited debt also relates to missing traders and cases under appeal and would have been classified as 'suspended' had it been transferred onto the Trader Register.[
37] The Department has been unable to give a detailed explanation and breakdown for all debt falling within this category.

27. In July 2002 the National Audit Office identified that approximately £300 million of the debt recorded on the VAT Mainframe had not been transferred to the Trader Register.[38] This discrepancy had not been resolved by March 2005, when the VAT Mainframe recorded £1.3 billion that was not reflected in the Trader Register. The Department identified that some £400 million of this was attributed to differences in the timing of updates to the two systems. The balance of £900 million represented debt that should have been transferred to the Trader Register. It estimated that that some £865 million of this debt related to missing traders and cases under appeal and was not immediately recoverable.

28. Although the Department started a feasibility study in January 2003, it did not address the problem until 2004/05.[39] The final phase of the IT project is due to be completed by the end of 2006.[40] The Department accepted that the resolution of this problem took longer than it expected and acknowledged that action could have been taken sooner. But it decided to use limited IT resources elsewhere in the department where it considered they would have the most impact and effect.[41]

29. The Department has acted on the biggest debts and progress is being made on the reconciliation.[42] £458 million of 'inhibited debt' has now been released to the Trader Register, of which £252 million has been suspended. A further £63 million has been cleared through adjustment, for example where a tax assessment has been replaced by a VAT return of a lower value, and £46 million has been received. The Department has written off or expects to write-off £52 million: £45 million, 87%, due to insolvency and £7 million, 13%, due to the age of the debt.[43]

30. As at 12 January 2006 the difference between the VAT Mainframe and the Trader Register stood at £943 million. Some £540 to £550 million of this difference related to timing. The Department estimates that a further £ 400million of debt will be transferred to the trader register when the final inhibitors are removed. It expects full reconciliation between the two systems to be completed in June 2006.


32   21st Report from the Committee of Public Accounts, The operations of HM Customs and Excise in 2001-02 (HC 398, Session 2002-03) Back

33   C&AG's Report, page R30, para 49 Back

34   ibid, page R30, para 50 Back

35   Q 23 Back

36   Q 17 Back

37   Q 35 Back

38   C&AG's Standard Report, page R24, para 13 Back

39   Q 40-41 Back

40   Q 101 Back

41   Q 12 Back

42   Ev 10 Back

43   Q 102 Back


 
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