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SPATA team
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SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/spata_team
TITLE: SPATA team
AUTHORITY: HM Revenue and Customs
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REQUEST_SLUG: spata_team
CAPTURED_AT: 2026-05-19T07:07:45+00:00
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- FOI2022_02759.pdf | https://www.whatdotheyknow.com/request/spata_team/response/1982448/attach/3/FOI2022%2002759.pdf?cookie_passthrough=1 | application/pdf | 1371892 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/spata_team/response/1982448/attach/html/3/FOI2022%2002759.pdf.html | | 0 bytes
================================================================================
MESSAGE 1 [outgoing]
HEADER: Don Edgley
2 February 2022
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
FOI2021/30787 makes reference to the "SPATA team" in an email sent 2nd November 2018 from: (CFO Group) On Behalf Of Holliday, Justin (CFO Group). This is in connection with replying to a letter concerning contractors who used disguised remuneration arrangements and the letter from the House of Lords sent to HMRC on 1st November 2018.
Please would you supply the following information:
1. Minutes from the meeting held by the SPATA team at 3pm (or whenever the meeting referred to took place)
2. Emails from the SPATA team to Jim Harra/Justin Holliday that reference this meeting between 2nd and 6th of November.
3. Finally please confirm what SPATA stands for.
Yours faithfully,
Don Edgley
================================================================================
MESSAGE 2 [incoming]
HEADER: FOI Central Team,
HM Revenue and Customs
2 February 2022
--------------------------------------------------------------------------------
Our ref: FOI2022/02759
Dear Mr Edgley,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 2 February.
We have allocated the above reference which you should quote if you need
to contact us.
We will arrange for a reply to be sent to you which will either comply
with our obligations under Freedom of Information Act or, if we think it's
an enquiry that we don't need to address under the terms of the Act, let
you know why. If it is the latter we will, if possible, pass it on to a
more appropriate part of the Department for answer.
While we aim to respond to all freedom of information requests within 20
working days, if for some reason this timescale cannot be complied with,
we will, where possible, write to you explaining the reason for the delay
and provide an estimated time for response.
Yours sincerely
HMRC Freedom of Information Team
================================================================================
MESSAGE 3 [incoming]
HEADER: FOI Team,
HM Revenue and Customs
24 February 2022
--------------------------------------------------------------------------------
1 Attachment
FOI2022 02759.pdf
1.3M
View
Download
Dear Mr Edgley,
We are writing in response to your request for information, received 2
February.
Yours sincerely,
HMRC Freedom of Information Team
================================================================================
ATTACHMENT TEXT EXTRACTION / OCR
================================================================================
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ATTACHMENT: FOI2022_02759.pdf
TEXT_FILE: FOI2022_02759.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 14
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--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’.
Text Relay service prefix number – 18001
OFFICIAL
Freedom of Information Team
S1715
6 Floor
Central Mail Unit
Newcastle Upon Tyne
NE98 1ZZ
Mr Don Edgley
By email: request-829672-
201c389b@whatdotheyknow.com
Email
foi.request@hmrc.gov.uk
Web
www.gov.uk
Date: 24 February 2022
Our ref:
FOI2022/02759
Dear Mr Edgley
Freedom of Information Act 2000 (FOIA)
Thank you for your request, which was received on 2 February, for the following information:
“FOI2021/30787 makes reference to the "SPATA team" in an email sent 2nd November
2018 from: (CFO Group) On Behalf Of Holliday, Justin (CFO Group). This is in connection
with replying to a letter concerning contractors who used disguised remuneration
arrangements and the letter from the House of Lords sent to HMRC on 1st November 2018.
Please would you supply the following information:
1. Minutes from the meeting held by the SPATA team at 3pm (or whenever the meeting
referred to took place) 2. Emails from the SPATA team to Jim Harra/Justin Holliday that
reference this meeting between 2nd and 6th of November.
3. Finally please confirm what SPATA stands for.”
I can advise that the acronym SPATA stands for Senior Public Appointees Tax
Arrangements. This refers to a process put in place following the ‘Review of the tax
arrangements of public sector appointees1’ in 2012.
Whilst this process has been superseded by other developments in this area such as the
public sector off-payroll working rules, the term SPATA has continued to be used internally
as a generic reference to the off-payroll work of the Tax Advisory Service.
The Tax Advisory Service team is part of the Accounting Operations Team and responsible
for ensuring the Department is compliant with its own requirements under UK tax legislation
and managing controls to mitigate any corporate risk. The team also provides professional
advice to the wider business on tax issues and supports the department’s financial controls
with off-payroll engagements
I can confirm that a meeting with the Tax Advisory Service took place from 15:00 to 15:30 on
2 November 2018. HMRC does not hold any minutes of this meeting, the outcome of this
meeting was communicated to Justin Holliday’s private office within the attached email
annex which falls within scope of your second question. Please note that where information
constitutes the personal data of officials to a degree which is contrary to their expectation of
privacy, this has been withheld under section 40(2) FOIA.
1 Review of the tax arrangements of public sector appointees (publishing.service.gov.uk)
--- PDF page 2 ---
2
OFFICIAL
If you are not satisfied with our reply, you may request a review within 40 working days of
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the
top.
If you are not content with the outcome of an internal review you can complain to the
Information Commissioner’s Office.
Yours sincerely,
HM Revenue and Customs
--- PDF page 3 ---
OFFICIAL
EMAIL 1 – 3 ATTACHMENTS
From:
(Corporate Finance - Finance Operations ) <
@hmrc.gsi.gov.uk>
Sent: 02 November 2018 16:04
To: Holliday, Justin (CFO Group) <justin.holliday@hmrc.gov.uk>
Subject: FW: For Justin : Urgent deadline Mon 5/11 House of Lords question ACTION: HoL Letter -
follow-up on DR] [OFFICIAL-SENSITIVE]
Importance: High
*Replied to Ruth et al
02/11
Justin
I have just finished the call with
&
on this and agreed this isn’t a question CFO can
answer.
As engagers, we are not in any position to check the tax affairs of our customers, and nor should we.
This role is seen to be elsewhere within the department.
Protocol is place with HMRC Tax Authority treats us (HMRC the customer) in the same as any other
of its customers. This restricts our access to relevant information under data confidentiality.
Tax Advisory Service
Corporate Finance
1 Ruskin Square, Croydon CR0 2WF
Tel:
Mob:
From:
(Corporate Finance)
Sent: 02 November 2018 12:59
To:
(Corporate Finance - Finance Operations ) <
.
@hmrc.gsi.gov.uk>;
(Corporate Finance) <
.
@hmrc.gsi.gov.uk>
Cc: Holliday, Justin (CFO Group) <justin.holliday@hmrc.gsi.gov.uk>;
(Corporate
Finance) <
@hmrc.gsi.gov.uk>
Subject: For Justin : Urgent deadline Mon 5/11 House of Lords question ACTION: HoL Letter - follow-
up on DR] [OFFICIAL-SENSITIVE]
Importance: High
- to confirm I have seen this email.
please review email and attached for us to discuss at 3pm (this is a
space query).
Corporate Finance - Finance Operations, Corporate Delivery
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--- PDF page 4 ---
OFFICIAL
Group Senior Responsible Manager – Worthing
ext
From:
(CFO Group) On Behalf Of Holliday, Justin (CFO Group)
Sent: 02 November 2018 12:23
To:
(Corporate Finance) <
@hmrc.gsi.gov.uk>;
(Corporate
Finance) <
@hmrc.gsi.gov.uk>
Subject: FW: [ACTION: HoL Letter - follow-up on DR] [OFFICIAL-SENSITIVE]
/
Can you help here at all?
I have sent through to Rob Woodstock Commercial but now think you may be able to help?
Sorry – very tight deadline.
Many thanks.
|Chief Finance Officer’s Private Office |HM Revenue & Customs |Room 2C/04, 100
Parliament Street London SW1A 2BQ |
From:
(CS&TD) On Behalf Of Stanier, Ruth (CS&TD)
Sent: 02 November 2018 10:10
To: Stanier, Ruth (CS&TD) <ruth.stanier@hmrc.gsi.gov.uk>; Fletcher, Kevin (CS&TD Centre for Data
Exploitation (CoDE)) <kevin.fletcher@hmrc.gsi.gov.uk>;
(CS&TD Centre for Data
Exploitation (CoDE)) <
@hmrc.gsi.gov.uk>;
(CS&TD DG Private Office)
<
@hmrc.gsi.gov.uk>; Holliday, Justin (CFO Group) <justin.holliday@hmrc.gsi.gov.uk>;
DL-Parliamentary Scrutiny Team <DL-
NAOParliamentaryCommitteeLiaisonTeam@internal.hmrc.gov.uk>
Cc:
(HMRC Parliamentary Scrutiny) <
@hmrc.gsi.gov.uk>; Jones, Nick
(Counter-Avoidance) <nick.jones@hmrc.gsi.gov.uk>;
(CS&TD Individuals Policy, Income
Tax) <
@hmrc.gsi.gov.uk>;
(CS&TD Centre for Data Exploitation (CoDE))
<
@hmrc.gsi.gov.uk>;
(Counter-Avoidance)
<
@hmrc.gsi.gov.uk>;
(CS&TD Centre for Data Exploitation (CoDE))
<
@hmrc.gsi.gov.uk>; Aiston, Mary (WMBC) <mary.aiston@hmrc.gsi.gov.uk>;
Julie (Counter-Avoidance) <
@hmrc.gsi.gov.uk>; Ciniewicz, Penny (CCG Director
General) <penny.ciniewicz@hmrc.gsi.gov.uk>; Harra, Jim (HMRC) <jim.harra@hmrc.gsi.gov.uk>;
Bristow, Carol (CS&TD Individuals Policy, Director) <carol.bristow@hmrc.gsi.gov.uk>
Subject: RE: [ACTION: HoL Letter - follow-up on DR] [OFFICIAL-SENSITIVE]
*Forwarded to Rob
too) for urgent attention
02/11
Justin/private office (Carol Bristow now copied in on the DR query)
This is a further follow up on the HoL Finance Bill sub-committee hearing Ruth and Theresa
Middleton attended last week.
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--- PDF page 5 ---
OFFICIAL
Can we have clarification on this question from the CFO perspective on what we can/should say on
this question raised by Lord Forsyth in the attached letter:
1) Whether any current or former HMRC contractors have used Disguised Remuneration
(DR) schemes
As you can see below there has been some discussion about taxpayer confidentiality in terms of
what HMRC discloses here (and whether we have this information that enables us to answer the
question). My understanding is that engagers of contractors will not know if contractors are using a
DR scheme.
Related to this, earlier in the chain,
has flagged that the SPATA data might help in the
response on contractors and that this is a Finance lead.
I have attached recent briefing on off payroll (3rd attachment). This is distinct from DR and therefore
does not cover it, but it does set out the numbers of contractors engaged by HMRC with reference
to HMRC’s annual report.
Grateful for the Finance view/cleared lines asap please, given the deadline to respond of 5th
November.
Thanks
Private Secretary to Ruth Stanier, Director General for Customer Strategy & Tax Design | HMRC |
Room 2C/23, 100 Parliament Street, London, SW1A 2BQ | Tel:
From: Stanier, Ruth (CS&TD)
Sent: 02 November 2018 07:42
To: Fletcher, Kevin (CS&TD Centre for Data Exploitation (CoDE)) <kevin.fletcher@hmrc.gsi.gov.uk>;
(CS&TD Centre for Data Exploitation (CoDE)) <
.
@hmrc.gsi.gov.uk>;
(CS&TD DG Private Office) <
@hmrc.gsi.gov.uk>
Cc:
(HMRC Parliamentary Scrutiny) <
@hmrc.gsi.gov.uk>; Jones, Nick
(Counter-Avoidance) <nick.jones@hmrc.gsi.gov.uk>;
(CS&TD Individuals Policy, Income
Tax) <
@hmrc.gsi.gov.uk>;
(CS&TD Centre for Data Exploitation (CoDE))
<
@hmrc.gsi.gov.uk>;
(Counter-Avoidance)
<
@hmrc.gsi.gov.uk>;
(CS&TD Centre for Data Exploitation (CoDE))
<
@hmrc.gsi.gov.uk>; Aiston, Mary (WMBC) <mary.aiston@hmrc.gsi.gov.uk>;
(Counter-Avoidance) <
@hmrc.gsi.gov.uk>; Ciniewicz, Penny (CCG Director
General) <penny.ciniewicz@hmrc.gsi.gov.uk>; Holliday, Justin (CFO Group)
<justin.holliday@hmrc.gsi.gov.uk>; Harra, Jim (HMRC) <jim.harra@hmrc.gsi.gov.uk>
Subject: Re: [ACTION: HoL Letter - follow-up on DR] [OFFICIAL-SENSITIVE]
I am uncomfortable citing taxpayer confidentiality in not answering whether we have used
contractors paid by DR. Don't we need to address this from a corporate perspective? Do we know
the answer to the question?
Ruth
Ruth Stanier | Director General, Customer Strategy & Tax Design | HM Revenue & Customs | Mob.
| Sent by BlackBerry
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--- PDF page 6 ---
OFFICIAL
--- PDF page 8 ---
4.8
Public Accounts Committee Hearing
HMRC Performance 17-18
Wednesday 5 September 2018
Page 2 of 2
Date16/08/18
Version No. 2.0
• There were no off payroll engagements in HMRC for Board members,
or senior officials with significant financial responsibility. There was one
interim Board member level engagement in VOA. The appointment
was approved by the VOA’s Accounting Officer and lasted for just over
4 months. The role is now undertaken by a permanent employee again.
Key message(s):
• In response to the intermediaries legislation reforms (known as IR35),
effective from 6 April 2017, we have reviewed all of our contracts with
suppliers, individual working practices for our contractors and the way
in which we engage off-payroll people.
• These reforms applied to public sector bodies and moved the obligation
to determine tax status from contractor to the engaging department.
• We have determined the employment status of all of our contractors
and have conveyed the IR35 status views to our suppliers.
• HMRC, as a public sector employer and engager of services, is
compliant with the reforms to the IR35 legislation. This has been
evidenced through reviews of our IR35 processes and governance by
our Internal Audit function and by HMRC in its role as the tax authority.
• Overall, contingent labour numbers have decreased as programmes
(Columbus) come to an end and more effective outcome based service
contracts are used.
--- PDF page 9 ---
Information is available in large print, audio and Braille formats.
Text Relay service number – 18001
Ruth Stanier
Director General
Customer Strategy and Tax Design
The Rt Hon. the Lord Forsyth of Drumlean
Chair, House of Lords Economic Affairs Finance Bill
Sub-Committee
House of Lords
London
SW1A 1AA
100 Parliament Street
London
SW1A 2BQ
Tel
03000 544855
Email ruth.stanier@hmrc.gsi.gov.uk
31 October 2018
Dear Lord Forsyth,
Draft Finance Bill 2018
I am writing to thank you for the opportunity to give evidence to the House of Lords
Economic Affairs Finance Bill Sub-Committee on the Draft Finance Bill 2018. You
requested some further information, and our responses are set out below.
Making Tax Digital for Business
The Committee requested a full list of organisation types that will be given a six month
deferral to mandatory MTD for VAT.
The six month deferral will apply to around 3.5% of mandated customers who fall into
one (or more) of the following categories: trusts, ‘not for profit’ organisations that are
not set up as a company, VAT divisions, VAT groups, those public sector entities
required to provide additional information on their VAT return (Government
departments, NHS Trusts), local authorities, public corporations, traders based
overseas, those required to make payments on account and annual accounting
scheme users.
The Committee requested the working behind the average cost figures, including the
full expected distribution of costs for organisations in different situations.
We published an updated Statement of Impacts on 1 December 2017. We can provide
more information about the underlying segmentation data on administrative burdens
and benefits to business. This is not available in an accessible format that we can
--- PDF page 10 ---
2
readily share this week, but we can provide a detailed response on this point within
the next two weeks. Further information about how we approached the impact
assessment is at Annex A.
Customer compliance
I can confirm that HMRC is assessing all the evidence collected by your Committee.
Our approach is also being informed by discussion with external groups, including at
HMRC’s Compliance Reform Forum. The Chartered Institute of Taxation, who are
members of the Forum, have been invited to discuss the issues and examples they
have raised with you there. We will also continue to engage with other stakeholders.
In addition, HMRC’s Board is establishing a Customer Experience Sub-Committee to
strengthen oversight.
The Committee asked how many settlements have been agreed over 5 years, and for
a more detailed breakdown of the terms on which the first 5,000 settled.
In July 2018 HMRC simplified the payment process for disguised remuneration
scheme users who wish to settle their tax affairs ahead of the loan charge. Scheme
users who currently earn less than £50k, are no longer in tax avoidance and settle
before the loan charge arises can agree a payment plan of up to five years without
any detailed paperwork.
For those who require longer to pay or with income of £50k or more, payment
arrangements are still available, but we would require more details before agreeing an
arrangement. There are no minimum or maximum time periods for payment
arrangements, and we will consider each on an individual basis.
To settle their affairs before the loan charge comes in on 5 April 2019, scheme users
were asked to register and provide the required information by 30 September 2018.
To date, over 24,000 scheme users have registered. We have committed to respond
by 30 November 2018, and are prioritising issuing settlement calculations to give
clarity to those who gave us the information required by 30 September. These include
scheme users who currently earn less than £50k, and we are in the early stages of
processing payment plans on simplified terms for this group. We expect that receipt
of settlement calculations will give more scheme users the information they need to
understand if they require instalment arrangements. HMRC is working hard to bring
all live cases to an appropriate conclusion.
We are not currently in a position to provide a detailed breakdown of income
distribution across different groups. We expect to be able to refine our analysis as
more settlement information becomes available.
Budget and Autumn Statement 2016 documents show the expected yield from this
measure to be £3.2bn by 2020-21, with 75% of that yield coming from employers. Our
records show that, of those who have settled their case so far, around a quarter are
employers, and they account for 90% of the recorded yield. The average settlement
yield for these employers is £525k. About one third of the employers have settled for
£100k or less and almost one third have settled for £300k or more.
--- PDF page 11 ---
3
The Committee was concerned about HMRC’s powers in respect of ‘Follower Notices’
and the penalties that could be incurred.
We wanted to provide some additional context. A person will incur a penalty in relation
to a follower notice where they fail to take action in response to the notice to give up
their use of particular arrangements. A person is liable to a penalty of 50% of the tax
advantage for a failure to take action on time. This can be reduced for cooperation to
not less than 10% of the tax advantage. Cooperation is in relation to the follower notice
itself and is defined in legislation. A person may appeal to the Tax Tribunal against the
decision that a penalty is payable and/or the amount of that penalty. Specific grounds
of appeal against the decision that a penalty is payable are set out in the legislation,
and include that it was reasonable in all the circumstances for the person not to take
action to remove the tax advantage.
I hope that this further information is helpful.
Yours sincerely,
Ruth Stanier
Director General, Customer Strategy and Tax Design
--- PDF page 12 ---
4
Annex A: Making Tax Digital for Business – further information about the
estimates set out in the updated Statement of Impacts
The model we use to calculate administrative burdens takes into consideration only
the costs and savings strictly related to compliance with MTD and meeting tax
obligations. It does not consider the wider benefits to businesses through improved
record keeping, better business management and a streamlined, digital experience.
These benefits may offset wholly, or in part, any compliance costs.
Standard Cost Model methodology was used to estimate administrative burdens
impacts and steady-state costs. To estimate savings and costs, the VAT population
with turnover above £85,000 was initially segmented by size, reflecting the differing
costs and requirements for small, medium and large businesses.
Each of these groups was further segmented to reflect the differing processes
currently employed to manage their VAT affairs, anticipated change with MTD and
their use of agents / accountants. Four segments considered those businesses that
largely managed their VAT affairs in-house (although adjustments for use of agents
were factored in), and a fifth segment considered businesses that completely rely on
agents to manage their tax affairs. The primary segments were:
Businesses using paper-based accounting moving to MTD software
Businesses using spreadsheet-based accounting processes retaining
spreadsheets, but using ‘bridging’ software
Businesses using spreadsheet-based accounting moving to MTD software
Businesses already using accounting software
Businesses outsourcing all VAT work (using agents)
Savings were estimated by considering the obligations a business fulfils in meeting its
tax obligations, from recording of sales to submission of a VAT return. Following
consideration of the current time taken on each obligation and the nature of the
burden, we ran impacts workshops, in which policy leads, HMRC VAT experts and
operational colleagues estimated percentage changes in time taken for each
obligation through operating MTD. Estimates were applied as appropriate within each
of the segmented groups.
Findings of the workshops were shared and tested with external stakeholders,
including the independent Administrative Burdens Advisory Board who advise HMRC
and their Customer Experience Working Group. An optimism bias reduction was also
applied to the estimated time savings.
Estimated costs were based on a combination of qualitative and quantitative analysis;
taking account of estimates provided by consultation respondents, commercially
available software products, internal customer insight and stakeholder discussion.
These costs were applied as appropriate across the segmented groups.
HMRC expects most businesses to incur some transitional cost in moving to the new
requirements. Those businesses already using accounting software or who currently
outsource VAT work to an agent or accountant are anticipated to see lower costs than
those moving to software systems from paper-based or spreadsheet systems. Four
primary components make up the transitional costs estimate:
--- PDF page 13 ---
5
●
training and familiarisation time for both new digital tools and new processes
(including opportunity cost of lost time to business)
●
purchase of new hardware or the upgrade of existing hardware
●
additional agent or accountancy costs (HMRC will also be providing guidance
and support to help businesses move to the new processes)
●
upgrading existing software and apps.
Estimated costs, with variances applied relative to the segmentation, were calculated
with reference to both qualitative and quantitative evidence. These variances reflected
both the complexity of the process change and the complexity of the business.