Modernising Revenue Scotland's tax administration framework – communications from Revenue Scotland to taxpayers: Consultation Analysis

3. Analysis Part A - Revenue Scotland’s Current Communications Framework

This section of the consultation document provided commentary on Revenue Scotland’s current communications framework with taxpayers and the background context for proposals for change.

The consultation posed the following question:

1. Do you agree that there are challenges with Revenue Scotland’s current communications practice, as described above? Please provide commentary to explain the basis of your answer.

Of those who answered this question quantitatively, the breakdown of views was as follows:

Reliability of paper-based communications

A common theme among respondents who agreed that there are challenges with the current communications framework was the reliability of postal communications.

Several professional bodies and individual respondents highlighted concerns about delays, inconsistencies and rising costs associated with postal services. One respondent noted that postal services have become less reliable in recent years, while another suggested that delays in postal delivery could increase the risk of taxpayers missing important correspondence and deadlines.

Professional bodies considered that paper-based communication can result in slower interactions between Revenue Scotland, taxpayers and agents, increasing administrative burdens and creating difficulties where deadlines are tight. One professional body also noted challenges arising from manual document handling and correspondence being lost in transit.

One professional body highlighted that disruption to postal services may increase the risk of unrepresented taxpayers missing important communications and deadlines, particularly in rural areas. However, the organisation also noted that some of the factors associated with poor postal access, such as rurality, can also be linked to digital exclusion through limited internet connectivity.

Opportunities and concerns relating to digital communications

Several respondents supported greater use of digital communications. One individual respondent suggested that a digital-by-default approach could provide a more accessible and cost-effective means of communication, while a tax representative body expressed support for digitalisation where appropriate safeguards are maintained. On the other hand, respondents also highlighted particular risks that come with digital communications, noting that these can be misdirected or lost, resulting in the communications not being received by the intended recipient.

Communication with agents and the Scottish Electronic Tax System (SETS)

Several professional bodies highlighted challenges associated with communications involving agents and third parties.

One professional body noted difficulties arising from fragmented access to client correspondence and emphasised the importance of supporting taxpayers' right to representation. Another professional body highlighted barriers to efficient communication between agents, taxpayers and Revenue Scotland and suggested that the Scottish Electronic Tax System (SETS) could be improved through greater consistency, clearer communication arrangements, and the ability for organisations to register more than one email address.

More generally, respondents considered that improvements to the accessibility and usability of SETS could enhance the experience of both taxpayers and agents.

Need for safeguards

A recurring theme across responses was that any modernisation of Revenue Scotland's communications framework should be accompanied by clear guidance and appropriate safeguards. Professional bodies emphasised the importance of ensuring that taxpayers understand their rights and options, and that any changes do not disadvantage those who experience barriers to digital engagement.