Department reveals details of proof of concept exercise through which it will investigate viability of introducing automated payment of goods tax, and how this could impact the future tax system
HM Revenue and Customs is undertaking a £1-m plus 18-month project aimed at better understanding whether technology could enable VAT payments could be split out in real time and sent straight to the tax agency.
The department has revealed details of a proof-of-concept exercise intended to “prove the technical feasibility of splitting digital retail payments to capture VAT directly”, according to commercial documents.
The potential implementation of an automated system would mean that “when qualifying goods or services are bought, the VAT within the purchaser’s payment could be routed to HMRC and the seller only receives the net amount”.
Most goods and services sold to UK consumers include an in-built tax of 20% meaning that, for every £100 spent, £16.67 ends up going to the exchequer with £83.33 ultimately being kept by the retailer.
To explore the feasibility of introducing a system for automatically sending these amounts to their respective recipients at the point of payment – and how doing so might affect tax policy and administration in the future – in late August HMRC entered into a £1.2m contract with payments technology Streeva. The UK-based firm has previously developed a platform designed to help charities automatically collect Gift Aid tax relief retrospectively. Its deal with HMRC runs until 31 January 2025.
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During that time, it will work with the department to explore how its technology – or something similar – could be used to directly extract VAT payments for goods bought by UK residents from overseas sellers not currently complying with their VAT responsibilities. The experiment, which will make use of simulated data sets intended to reflect real-life transactions, will cover both card payments and those made by bank transfer or digital wallets.
If the proof of concept demonstrates sufficient potential in the context of collecting VAT from overseas entities, HMRC the exercise “would begin to inform whether or not a first potential use for split payment in the UK is viable [and] could then also help shape future tax modernisation efforts, [such as] automated software which could link businesses, payments intermediaries and HMRC”, according to the text of the contract.
HMRC believes that any such point-of-sale means of directly collecting VAT “would be driven by either payments system messages – [such as] the location of a seller or a buyer – or new data sources, [such as] product codes, e-invoices or equivalent”.
“Currently, as far as we are aware, there are no marketed solutions available, and we are not aware of others asking the market to develop such solutions,” the contract adds.
The project will be split into three phases, the first of which aims to demonstrate whether splitting systems can deliver the “basic capability… to intuit and discern” from the available data that a transaction is VAT-taxable – and then to apply the relevant split to the payment.
The second phase will focus on the technology’s ability to infer from payment data whether or not the seller is complying with their VAT duties, and then collate this information for HMRC use.
If and when this capability has been proven, the department also wishes to investigate whether technology could potentially “extract the tax from a payment before that payment leaves the regulatory jurisdiction in which the buyer is resident… [which], in a UK context means a mechanism that can make a splitting intervention for VAT before the monies are transmitted overseas to a sellers’ deposit account”.
The final phase of the exercise – which HMRC believes will account for the majority of its work with Streeva – will explore ways in which greater sophistication could be built in to a splitting system, including the use of external data sources to inform decisions.
The ultimate aim of this work will be to understand how such a system’s “capability might be further developed for real-time collection of VAT [or] general sales tax – by tax authorities around the world”.
Beyond the fundamental technical feasibility of introducing technology that could deliver these capabilities, the proof of concept seeks to understand the extent to which an automated VAT-collection system “would be interoperable with existing and any foreseeable future payments networks or systems. The exercise will also consider whether the automatic splitting could have a negative impact on payment-processing speeds, or cause any complications when issuing refunds.
The exploratory project takes place against a backdrop where various countries – but not the UK – automatically collect value-added or sales taxes via “through legislatively mandated interventions on payments”, according to the contract.
“Overlaying such technology on the UK VAT system would not be possible without first addressing a wide range of complex policy questions and understanding the full potential of any such technology,” the document adds. “In order to test the potential of the technology, our initial focus is on exploring the feasibility of splitting payments in a specific area of VAT for goods and services bought by UK consumers from non-compliant overseas sellers. This will test a range of capabilities, including the technology’s ability to know when VAT is chargeable or not. Also, whether an intervention can be made without the consent of the seller or buyer, something that, as far as we are aware, known examples of split payment are unable to do.”
Commercial documents indicate that the main supplier Streeva will work with three subcontractors: digital government specialist Public; professional services firm EY; and the University of Portsmouth.