This week's opinion: 8 July 2021

Among the items which crossed my desk this week were the decisions in the Wilkes case on the high income child benefit charge and the Office of Tax Simplification report on third party data (see tinyurl.com/otstpdavision and the news item on page 4). 

On the face of it these are distinct issues but there is a connection. Whatever one thinks about the child benefit charge policy it is undeniable that its implementation has created huge problems. At least part of this must be down to data. A constant theme in appeals against penalties for non-disclosure has been to say ‘HMRC knows how much I earn and how much child benefit my family receives – surely it can put the two together’. I think that we can all have sympathy with this view while acknowledging that it is not quite that simple. I suspect that HMRC knew full well that the charge would be a nightmare to administer but had no choice given the ministerial decision. 

The OTS report makes valuable contributions to the debate on the role of data in tax administration and we will review it fully soon in Taxation. But what shone through for me in my initial reading was its emphasis on the importance of not thinking about data and policy in separate vacuums but on bringing them together at an early stage, so that a new policy is supported by the data rather than undermined by it. Although the report is mainly about third party data, much of its thinking is surely applicable to the sharing of data within and between government departments.