Some challenges for the Banking Code

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A banker of my acquaintance sent me the following list of challenges for the Banking Code:

  • Banks should be asked to sign up at Board level
  • The code will apply to all taxes
  • Banks should be encouraged to issue a press release to confirm when they have signed
  • Banks that have signed up may be allowed to use the tax pay tick
  • Banks will agree to be subject to 3 monthly real time audits of their tax affairs
  • Banks will be asked to sign up their tax staff to an ethical code (either their own if approved by HMRC, or one attached as an appendix to the Code)
  • Banks will be encouraged to have the same compliance approach to all their companies and branches (even those the business of which may not be strictly banking), where so ever located
  • Banks will have to keep records of all material tax advice so that this can be inspected by HMRC
  • Banks will authorise their auditors to speak directly to HMRC at half year and yearend to check compliance with the code
  • HMRC will form an expert committee with the BBA and LIBA to discuss issues
  • HMRC will seek the advice of selected tax professionals who will advise them of any issues
  • HMRC will issue guidance and informal clearances when banks have questions about what is the spirit of a particular law.  Banks should contact their CRM for this purpose.
  • HMRC should provide training material for accounting and legal firms
  • I like it.

    What this proves is two things:

    1. There are bankers who think appropriately
    2. The willingness to comply can be found.

    Now it’s time for delivery.