Making Tax Digital may not make it easier for everyone.

What do you think:

  • Doing tax returns on line is a breeze?
  • No need to worry because your accountant does it all?
  • Perhaps you might need to tell HMRC if digital tax is going to be difficult?


Her Majesty’s Revenue and Customs (HMRC) is planning a new approach that should end all that form filling each year to tell them about what you’ve earned, received in interest and other income so that your tax can be worked out.    By getting regular information from employers, banks and building societies, they will have lots of the information already so that you just need to add anything extra – and all this will be possible through a computer or smart phone – meaning that you can see at any time what you might need to pay in tax.  Self-employed people and businesses will also have a better and up-to-date idea of their tax situation by sending HMRC regular information and getting their own tax forecasts –again, all possible on-line.

You can read about their proposals in a series of consultation documents.  I recommend “Better use of information” for anyone and “Simplifying tax for unincorporated businesses” and “Bringing business tax in to the digital age” for those running their own businesses –they give examples of how the new system will work. There are other documents too for those who want to look at more detail.

But sending and getting financial and tax information on-line may not suit everyone – especially if using computers or smart phones is difficult because of a disability or other circumstances so it is worth checking out their proposals and telling HMRC what you like and what you don’t.  You can send comments to them until 7 November 2016 by e-mailing:

Below are the comments I have sent in – if you are short of time, feel free to use any of this in your own response.

Overview:  The concept of MTD has many merits but the paucity of equality (and especially disability) considerations places the initiative at risk.  It is not clear how current proposals and potential law will satisfy the judgement in Bishop & Others v HMRC Commissioners [2013] 522 UKFTT).  If these changes don’t work for “ordinary working class people”, the Department will undermine the Prime Minister’s statements and, probably more importantly, fail to produce the increased tax, lower costs and public endorsement needed.

The following comments relate to the principles of five of the 6 MTD consultation documents (plus some comments on delivery detail).

  1. Better use of information.

Principles.  It is very surprising that HMRC has already concluded that MTD will not have “a significant or disproportionate impact” on people with protected characteristics when the Department has neither undertaken an equality impact assessment nor specifically asked questions about such in any of the consultation papers.

The stated percentage of people with access to digital tools is without reference to the source data or context and appears, wholly erroneously, to be linked with whether customers are digitally excluded.  While the MTD principles are sound, they are substantially undermined by the lack of data and detail about those customers who will encounter most difficulties (for whatever reason) in adopting MTD.  In this post-Brexit fragile economy, giving high priority to those most likely to be disadvantaged is likely to improve the system for all and make better political, social and economic sense.

While increasing numbers of people have access to digital devices, many avoid using such in relation to their finances due to the very high level of on-line fraud.  HMRC needs to present a stronger description of the security measures before such is convincing.  Likewise, personal security of passwords and security codes is increasingly risky as people now have so many – security alternatives or guidance on secure storage using IT should be available.  Ideally, customers should have one code for all interactions with Government.

Delivery detail.  Frequent system-generated prompts have a high risk of being ignored by customers who have to separately find and enter passwords/security codes just to discover information of little value/action. Customers should be able to switch off prompts except those requiring action to comply with the law but with options to receive prompts that are to their benefit, for information etc.  Many will not want any contact unless something has gone wrong.

Third party information (including that from other Government Departments) should always include specific account details and payment dates, percentages attributable to joint account holders and should be in the standard format contained in their own Equality Act-compliant notifications to customers to facilitate checking by those customers.  Employees should be able to confirm that current NI is being paid by their employers.

Obviously MTD requires testing with various adaptive soft and hard ware of varying vintages across the full spectrum of broadband speeds.  On-line instructions and guidance should be capable of downloading in various formats (e.g. large print from a Word document) for ease of referral.  Use of on-line links and text boxes can be difficult with some adaptive software.  For some people, transferring a security code to a screen text box will be very difficult – the option to receive via e-mail should be available.  Digital tax account displays should be very simple and accessible with all types of adaptive software.

HMRC must also utilise the same short-cut key strokes as Microsoft e.g. Control P to print – otherwise, they would be requiring those using such with adaptive software to learn yet another keyboard “language”.

  1. Simplifying tax for uninc businesses.

Universal Credit (UC) is mentioned in this document (and elsewhere) but full implementation  may be subject to further delays hence MTD should take account of interactions with Working Tax Credits, Housing Benefit, ESA “permitted work”, New Enterprise Allowance, potentially Access To Work and possibly other benefits/payments.  The proposals would be significantly strengthened by DWP and HMRC commitments regarding payment reporting and timescales both before and after full UC implementation – again, giving high priority to those most likely to be disadvantaged.

  1. Simplified cash basis for uninc property business.

(Not read)

  1. Bringing business tax in to the digital age.

With self-employment at an historic high  plus the post-BREXIT economic uncertainty and recession risk, considerable care is needed to avoid many small businesses (regardless of legal status) failing due to the pressures of MTD – and so increasing the numbers of unemployed/benefit claimants.    If MTD becomes just too difficult and/or too expensive, people may just give up – creating unacceptable political, social and economic risk.

Consequently, every aspect of MTD introduction should be tested at the level of the most vulnerable businesses – rather than the scenarios currently used.

Many of these businesses will barely use IT for business, may need to purchase new hard and software and, most importantly, learn how to use it.  This represents burdens in time, cost and business owners’ confidence and commitment.  The proposals in this area are not yet sufficiently developed with cross-Departmental input.  For example, there is no mention of how all New Enterprise Allowance providers (or similar other projects) will be required to deliver MTD training, how Access To Work funded support workers will be upskilled or on how other agencies (local Councils, Skills Funding Agency and more) will support the implementation.

HMRC can obviously identify those self-employed and other businesses that currently have no or very limited IT interactions   with the Department but it is not clear how this consultation or any concept testing has been undertaken directly with such customers.  This would also provide a more meaningful assessment as to whether the proposed £10K threshold for mandatory MTD is meaningful and realistic, how it relates to WTC, Housing Benefit, UC, personal tax allowances and how it will be automatically adjusted in line with the wider economy.  Direct concept testing with the most vulnerable would also amplify the “other reasons” justifying MTD exemption.

Recognising the Government’s goal of halving the disability employment gap and that working disabled people are more likely to be self-employed than their non-disabled peers, there is little evidence that their needs have been sufficiently addressed.  It is not evident that Government has been successful in achieving compliance with the Equality Act regarding reasonable adjustments, accessibility or information available in alternate formats across either its own digital products or the external software developers with which it works.  This tends to undermine any suggestions that systems will be fully inclusive for those with additional needs –whether due to low literacy, numeracy or IT skills or reliance on adaptive technology.

Overall, it is disappointing that HMRC does not report what evidence it holds showing that MTD will have no significant or disproportionate impact on customers with Equality Act characteristics.  Proliferation of SMART phone ownership is surely not a convincing basis upon which to rely upon in gauging those owners’ ability to use such for MTD?

  1. Tax administration.

Setting aside the issues of deliberate cheating or aggressive tax avoidance, it might be expected that an aim of MTD to reduce the levels of non-compliance, errors, late submissions/payments etc. would be supported by evidence of current performance and goals set for improvement.  These would seem to be basic measures for assessing the value of introducing MTD and its long-term effectiveness.

Additionally, compliance data relevant to different groups of individuals (for example, by protected characteristics) and/or types/sizes of businesses plus current means of filing would demonstrate HMRC Equality Act duties while highlighting risk areas for non-compliance by volume, value and such characteristics.

This would then assist MTD design to mitigate risk and improve performance.

  1. Voluntary payment.

The business finance rationale of voluntary tax payments far in advance of their due date requires strengthening if reductions in working capital, loss of interest and demonstrable assets is to be justified.  For those with most need to budget for their tax, there is a risk that such payments could become analogous to pre-payment utility meters with the associated adverse publicity

Penny Melville-Brown OBE

Disability Dynamics ltd

Helping disabled people to work since 2000

Trump: another of the rich and powerful being a law unto themselves?

What do you think:

  • Is fame the ultimate excuse?
  • Where do we draw the line: assault, murder, genocide?

 Trump’s comments revealing his attitude and behaviour towards women were awful enough.

But isn’t the main point that, in his experience, he could get away with such behaviour because he was a “star”?

We’ve heard it before: movie and sports stars, politicians and more whose crimes have been protected, obscured, ignored and tolerated by the hangers-on who benefit from them.

Isn’t this the root of the Jimmy Saville story: decades of sexual assault on children protected by his “celebrity”?


Penny Melville-Brown OBE

Disability Dynamics ltd

Helping disabled people to work since 2000

Disability and the built environment is more than just lifts and ramps.

What do you think:

  • Wheelchair users have led the way but who else needs accessible homes and buildings?
  • What already makes it difficult to get around?
  • Will your home still work for you when you are older?


Its good to contribute to this Parliamentary enquiry in to disability and the built environment but, while I have worked with thousands of disabled people over the years, I’ll stick to my own experience as a blind person and hope that many others also send in their ideas (closing date is 12 October).

I have thought about what stops me using many public spaces.  Lifts and ramps are obviously helpful for people who can’t see like me as they avoid the hazards of negotiating steps.  But sound is probably more important and largely ignored.  Very many modern buildings are full of hard surfaces that reflect noise, people talking, moving and being naturally active and, on top of it all, music that is too loud and intrusive.  These environments can be torture of the bucket-over-the-head-being-beaten-by-a-hammer ilk.  Sound that has degenerated in to noise removes a blind person’s ability to listen to the environment and understand it, to hear one’s guide and be safe in moving around.  I remember years ago trying to explain this to the developers of the Blue Water complex.  So one simply avoids going to noisy shopping centres and similar environments.  Some are not possible to avoid such as train stations with the tannoy systems, engine sounds, guard whistles and passenger hustle and bustle.  Trying to negotiate platforms full of people and luggage without being able to hear what the assistant is saying can be truly a leap in the dark.

I wonder whether people with mental health conditions find noise equally difficult?  And those with hearing impairments will have their own tales to tell.

Space is another major issue.  It is not just the narrow aisles in the supermarkets but corridors in hotels and small spaces in other buildings.  Many, but certainly not all, can accommodate a wheel chair user but designers have rarely considered the blind person who is being guided: there needs to be sufficient space for two people alongside each other.  I cannot count the number of times I have had my knuckles bloodied by being run in to a wall or other obstacle because there wasn’t enough space.

High contrast décor was really helpful when I had a bit more sight.  It doesn’t need to be intrusive but perhaps contrasting skirting boards and door surrounds.  I remember being stuck by the wash-hand basins in some toilets – all white probably looks bright and sterile but I had to beat on every vertical surface until I found the one that was the exit door!

Lastly a practical note on public spaces borne from delivering workshops at many different venues, that old chestnut: hearing loops are just useless if no-one knows that they are there, they are not maintained and no-one knows how to switch them on!

Thinking about the domestic built environment, I have been hugely lucky to have both a great architect and builder who have taken on board my needs: doors without thresholds, safe steps, tactile paving, accessible controls and electrics, non-slip flooring and much more.  I love designing my building projects right down to the detail of flush cupboard door handles that don’t catch me.  I am lucky enough to have the experts that can make it all happen but they are quite a rarity –do Trusted trader systems include a “disability and accessibility” comment box?  But I didn’t even contemplate that manufacturers are producing mirror-finished walk-in shower bases   that, with water and soap suds, are as hazardous as an ice rink.  After more than a year, the injury from the fall is still not recovered.  When many of us are replacing baths with more accessible, economic and environmentally-friendly showers, there should be an absolute prohibition on fixtures and fittings that actually create risk.  And don’t even suggest those non-slip mats that so quickly become mouldy and hazardous in their own right that the shop assistant strongly recommended against buying one!  I resorted to non-slip textured paint that has done the job but why should I need to?

Regarding Government and policy considerations, the narrow thinking about accessibility in public buildings and housing developments flows from decades of Departments and Councils largely giving the breadth of equality legislation scant regard – so it is little wonder that most associated with the construction industry   simply do the same.  I used to be a member of a local Access Group but we needed help to build the relevant planning expertise, funding for at least our travel costs, proper consultation processes and accreditation by the Local Authority to be credible across both the community and industry. Stronger leadership, effective legal compliance and more attention to the details that affect a very broad constituency of citizens would make a difference – and we all know that it needn’t cost much if tackled at the design stage.

“Accessibility” measures and building regulations have opened up the built environment for many but still haven’t removed the physical risks for lots of us.

Penny Melville-Brown OBE

Disability Dynamics ltd

Helping disabled people to work since 2000

The Great Escape

At Moorfields eye hospital yesterday having utterly disgusting surgery on my eye – not going to do anything for my sight but might make it more comfortable in the future: a conjunctival flap so it will all look a bit grey and opaque for at least a while.

But the real nightmare was the prospect of having to stay in the hospital overnight.  Thank goodness for my wonderful niece Emily who took time out from her stage management course at RADA to rescue me.  She was wonderfully patient as I got more and more irascible and impatient to get out!  And I was really disappointed that she hadn’t brought a parrot to go with my great eye patch.

We managed to flee at about 2000 for a taxi together to waterloo and then all the station staff and my home taxi driver looked after me every step of the way.  Good to be in my own bed at last by nearly midnight and today the girls here have been ministering, sorting out all the drugs and putting up with my brain that is shot to hell with the remnants of the sedation.  So I’ve awarded myself the day off!

Will be back to normal service tomorrow and, definitely, next week.


Penny Melville-Brown OBE

Disability Dynamics ltd

Helping disabled people to work since 2000moorfields-escape

Equality governance could answer structural, institutionalised discrimination and unfairness.

What do you think?

  • Are we already seeing those disempowered and distanced by inequality kicking back at privilege and “authority”?
  • What happens when policies actively increase disadvantage and deprivation?
  • Where is the leadership and accountability to make life fairer for everyone?

Equality and fairness are in the headlines: from Theresa May’s first Prime ministerial statement and the flak around Sports Direct employment practices to the disability employment gap and the critical Equality and Human Rights Commission reports on gender pay discrimination and race inequalities.  We seem to be facing increased polarisation between the influential “haves” and the disempowered “have-nots” that is already putting political, economic and social security at risk.  In effect, we have structural and institutionalised inequality and discrimination – not just a side-issue of decisions but a direct consequence of policy over many decades.

My starter-for-10 answer is that the Board of every Government department, public sector body, business, charity   and other organisation should have at least one person responsible for equality and fairness governance covering employment and services.  This isn’t just the rather lame “champion” but a remit equivalent to financial probity, operational effectiveness etc. – and with similar accountability.  With little cost, our society’s structures will get the nudge to re-focus rather than revolutionise their activities – before it gets too late to manage increasing public and customer disaffection.

Inspiration comes from the report on “Devolution and disadvantage in the Sheffield City Region: an assessment of employment, skills and welfare policies”  which calls for “inclusive governance at the City Region level”  covering governance of Local Economic Partnerships, other geographic levels and employment programmes – a good start but not far enough!  And, of course, it feels good to have the Help to Work and Work for Yourself projects that we delivered getting coverage in this study.

Section 4 of the report describes how policies can restrict access to employment and skills support: the cuts caused by austerity measures have more negative impact on those already poor and disadvantaged (whether or not they are working).  This is further exacerbated in areas of existing high deprivation such as Bolsover and Barnsley because welfare reform policies have specifically sought to reduce eligibility for disability benefits when residents within these former mining areas have higher levels of long-term health conditions.  The seemingly arbitrary benefit sanction regime piles on the pain, causes mass destitution and drives many out of the benefit/back-to-work support systems – and is even more significant in the deprived areas because ESA sanction levels are higher than for JSA.

Essentially, all this describes how policy is creating an underclass of deprived and disadvantaged people increasingly detached from the structures that make our society work – it sounds like a breeding ground for dissatisfaction and dissent.  Presumably there is a policy risk assessment as to the tipping point after which the misery turns in to action – and perhaps we are already at that point with the BREXIT vote being the first and, thankfully, democratic manifestation of public unrest?  How long will they be able to keep the lid on before the pot boils over?    How much of this is already echoed elsewhere as other countries see mass dissatisfaction with decision makers too elevated from the reality of their policies?  Perhaps they need to recognise that political stability and popular engagement are as fundamental to economic strength as improving devolution and infrastructure – surely there are enough historic and global  examples of what happens  when the most down-trodden revolt?


Penny Melville-Brown OBE

Disability Dynamics ltd

Helping disabled people to work since 2000

Blueprint for one million disabled people to get back to work awaited.

What do you think:

  • Got some ideas for the Work and Health Programme Green Paper that’s due?
  • What happens to vulnerable people repeatedly set up to fail?
  • If employers won’t change, what will?


There are nearly 7 million disabled people of working age in the UK but over half (3.6m, 53%) of them don’t work (compared with some 20% of non-disabled people).    To meet the Conservative manifesto of halving this employment gap by 2020, over a million more disabled people need to get work in the next four years!

This looks like a hugely over-optimistic pledge taking account of the very tight timescale with tiny (0.1% progress since 2015), no Government having achieved significant success over decades and the limited funding of the main delivery vehicle: the Work and Health   programme.

The Government is about due to issue a Green Paper on this new Programme.  I strongly commend the Learning and Work Institute paper with ideas about how the Programme should be shaped and funded.

From my perspective, all this ambition risks foundering without a major change in employer attitudes and behaviour – the job market is already massively restricted by more than half of small and medium sized businesses admitting that they discriminate when recruiting.

Once again, I champion self-employment as a potent alternative (already highly favoured by many disabled people) but this needs wholescale re-design of New Enterprise Allowance and proper integration with HMRC’s current Making Tax Digital ambitions and accessibility channels.

Based on the 20% success rates for disabled people achieved by the Work Programme and Work Choice, the pool of 3.6 million unemployed disabled people seems just too small to achieve the Government’s goal.  The situation is even more challenging when the pool includes significant numbers of ESA/IB claimants for whom these two programmes had even lower success rates (about 12%).  Additionally, many (47%) within that pool have limited work interest/capacity.

In real terms, future interventions might not achieve many more than about 2 million disabled participants   and so would need 50% success rates – a massive leap over past performance for those receiving ESA/IB.

With Jobcentres taking on more responsibility for long-term JSA claimants, most of the future Work and Health Programme funding of about £400 million (up to 2020-21) is likely to be aimed at disabled clients.  It sounds a lot until considering how the funds will be spread across 2 million participants/1 million work successes.

In reality, at this funding level, the “halving the employment gap” by 2020 is clearly not feasible and nor is participation by 2 million people.  The Programme Green Paper is only due to be issued in autumn 2016 so there is even less time for implementation and delivery.

Targeting interventions on volunteers who are keen to take part and work could be most cost-effective: avoiding expenditure on enforcing “mandatory” participation, offering employers the most motivated job applicants, providing success role models for those currently reluctant and demonstrating that interventions succeed.

But success rates need to be excellent and multi-faceted.  Not everyone will get work but even those who don’t must achieve life improvements (whether more social inclusion, better health, increased independence, new skills etc.) so that each individual, various public services and society as a whole all benefit and become enthusiastic champions of the interventions.   Like any other experience, bad reviews have longer reach than good and, for individuals who are repeatedly set-up to fail by poorly designed and ill-funded interventions, their life prospects can be irrevocably damaged.  They are more likely to join a cadre of people who are highly resistant to employment interventions as their risk-aversion to attempting work is reinforced.


Penny Melville-Brown OBE

Disability Dynamics ltd

Helping disabled people to work since 2000

Project manager opportunity.

What do you think:

  • Got the skills and experience to manage this project?
  • Understand how entrepreneurial skills can open up employment?
  • Enthusiastic about supporting unemployed people back to work?

Here is a chance to make a difference in a short-term contract as a part-time project manager delivering enterprise support for unemployed and economically inactive people in the Sheffield City Region (which extends to parts of Derbyshire and Nottinghamshire).  I was involved in part of the bid writing and think this project has lots of possibilities.

Click here for further information

Penny Melville-Brown OBE

Disability Dynamics ltd

Helping disabled people to work since 2000