Dear HM Revenue and Customs,

Using HMRCs own figures, the likely financial effect from the 2019 Loan Charge will be £2.53bn and will effect approximately 40,000 individuals. Based on those estimates, the average debt HMRC will be seeking to recover from individuals is £63,250. Given the average UK income is £27,884 gross, this will likely cause significant financial hardship for many individuals.

Mel Stride has stated publically "HMRC are able to help taxpayers who are not able to pay their taxes and will work with those who are in genuine difficulty".

With that in mind, my questions are as follows:

-What are the "time-to-pay" time frame guidelines the HMRC debt recovery unit uses?

-What is the maximum "time-to-pay" time frame the HMRC debt recovery unit has allowed in the past 24 months?

-Are HMRC planning or prepared to take any special and/or specific considerations into account when working with individuals who will have difficulty in paying?

Yours faithfully,

Mr Are Sea

Dear HM Revenue and Customs,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of HM Revenue and Customs's handling of my FOI request '2019 Loan Charge notifications'.

4 separate FOI request questions were grouped together and refused under s12(4) of the FOIA, with reference to regulation 5 of The Freedom of Information and
Data Protection (Appropriate Limit and Fees) Regulations 2004 [known as the Fees Regs],
when estimating the cost of complying, HMRC may aggregate two or more requests made
by the same person, when the same or similar information is requested and where those
requests are received within a period of sixty consecutive days.

I would like to argue that the questions grouped together do not fall under the same or similar information requested. They all require separate answers from separate areas of HMRC in relation to separate subject matters.

FOI request one asks:
-What date (month and year is fine) was the first Contractor Loan Scheme declared to
HMRC?
-What date (month and year is fine) did HMRC send out their first personal
communication, via letter or email, to a scheme user advising them that they
considered their scheme Tax avoidance?

The answer to the first question should be easily available and the second should also be easily accessible within the timeframe given to answer of 3 1/2 days. Both are asking for one specific form of communication and the month/year said communication was received/dispatched. This question is an administration based question likely contained and easily available within HMRCs internal systems. I would expect both to be answered within guidelines of Freedom of Information Act 2000.

The second FOI request asks:
-Excluding having a page with information on the HMRC website, how many
customers have HMRC individually contacted, through either letter or email, to advise
them of the May 31 2018 deadline to register for settlement?”

The answer to this question is quite separate to the others. It asks from HMRCs Counter Avoidance Team how many letters they have sent out notifying people of a settlement registration deadline. This is a different subject matter, should not be grouped with the other questions and I would expect it to be answered within guidelines of Freedom of Information Act 2000.

The third FOI request asks:

-What specific recommendations the Nudge Unit has given HMRC in regards to
sending out Advanced Payment Notices?
-Which of those recommendations HMRC has employed?
-How many customers have been targeted by the Nudge Unit recommendations that
HMRC has chosen to use in relation to APNs?
-What specific recommendations the Nudge Unit has given in regards to how HMRC
should approach the 2019 Loan Charge with its affected customers?

The answer to this question is quite separate to the others. It asks from HMRCs Behavioural Insights team what recommendations they have made in relation to APNs and the Loan Charge. This should be easily available in the timeframe- these recommendations have been put into practice by HMRC, staff would need ready access to them to be able to implement them therefore I have no doubt they are readily available. This is a different subject matter, should not be grouped with the other questions and I would expect it to be answered within guidelines of Freedom of Information Act 2000.

The fourth FOI request asks:

-What are the "time-to-pay" time frame guidelines the HMRC debt recovery unit uses?
-What is the maximum "time-to-pay" time frame the HMRC debt recovery unit has
allowed in the past 24 months?
-Are HMRC planning or prepared to take any special and/or specific considerations
into account when working with individuals who will have difficulty in paying?

The answer to this question is quite separate to the others. It asks from HMRCs Debt Recovery unit what recommendations they are working from. This should be easily available in the timeframe- these recommendations have been put into practice by HMRC, staff would need ready access to them to be able to implement them therefore I have no doubt they are readily available. This is a different subject matter, should not be grouped with the other questions and I would expect it to be answered within guidelines of Freedom of Information Act 2000.

I understand that I do not have to specify particular files or documents and it is the departments responsibility to provide the information I require. If you need further clarification please contact me via this website. If my request is denied in whole or in part I ask that you justify all deletions by reference to specific and legally relevant exemptions of the act. I will also expect you to release all non-exempt material.

If you refuse to answer my foi requests in whole or in part without providing a specific valid exemption for each refusal I will escalate my complaint to the information commissioner.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/2...

Yours faithfully,

Are Sea