HMRC use the phrase to mean all those advisers who file tax returns or claim forms on behalf of clients. HMRC say this includes accountants, tax advisers, solicitors, payroll bureaux and VAT advisers. It also includes all such advisers who are members of one or more professional bodies and also all those who have no professional qualifications.
There is no definitive list of tax agents so we are reliant on HMRC figures and here I am struggling. The references below are to paragraphs in their recent con doc: "Working with Tax Agents".
- At para 1.2 it states that 70% are affiliated to one of the main professional bodies within the UK. And then goes on to say that 80% of agents have a professional qualification. The implication being that 10% are qualified but no longer affiliated. Even if this were the case, how would HMRC know? It seems to me that either the statistics are spurious or that HMRC has more information about tax agents than has hitherto been revealed.
- At para 5.2 it states that "at least 12,000 tax agents in business in the UK are unaffiliated to any major professional body." I wonder how this figure has been determined. Given the figures noted at para 1.2 it implies that this represents 30% of the tax agents and that, therefore there are only around 40,000 tax agents in the UK. This accords with the figure quoted on page 5 of the Impact Assessment; this states that “there are approximately 43,000 tax agent establishments in the UK who act for more than five clients.”
- At para 5.10 it states that HMRC currently recognise 80,000 agents who act for less than 5 clients, including friends and family and those supporting the not for profit community. This seems to be twice the total number of tax agents previously identified. And yet it is clearly intended to be a minority of the total number of tax agents recognised by HMRC. According to the Impact Assessment this 80,000 figure is over and above the 43,000 tax agents who act for more than 5 clients. But this fact is not made clear in the con doc itself.