CIPP response to the HMT Travel and Subsistence: discussion paper

17 December 2015

The CIPP Policy & Research Team ran a survey from 21 October to 19 November 2015.

The submission looked to provide survey responses and commentary from a wide range of stakeholders within the Payroll Industry that will influence the policy development of the Tax rules for travel and subsistence costs that arise and that are reimbursed to employees by their employers as they travel within the course of their work.

CIPP response to the HMT Travel and Subsistence: discussion paper

Summary of key findings

  • The CIPP policy & research team ran a survey from 21 October through to 19 November 2015. The survey results can be found in appendix 1.
  • From the survey we can see that support for the framework and principles discussed within this paper is evident, but, and as we would expect from members of our industry, we look forward to seeing the detail that will yet follow.
  • The ongoing need for clear and detailed guidance is evident from many of the survey responses.
  • Guidance needs to be produced that addresses the needs of different users such as employees, employers, software developers and technical writers. Different users also work to different timetables with software developers and technical writers/education sector requiring the longer lead in time.
  • There is evidence that different industries/sectors have widely different decision making processes when it comes to the administration of their travel and subsistence policies. What is apparent from the survey responses is in certain sectors the employee has little choice but to comply.
  • The decision to make a workplace within the home is not a matter of personal convenience or tax advantage for the employee.


The CIPP recognise that in an increasingly digital world, widespread hunger for detail is no longer evident for the majority of the working population. However, to ensure clear and accurate interpretation and subsequent compliance for the new framework and principles, clear and detailed guidance needs to be produced at a much earlier stage than is currently being delivered with new or adapted tax policies that are being delivered to achieve simplifications.

Certain industries/sectors will need greater protection as a result of the proposed changes, the public sector, particularly emergency services, have developed processes and practices aimed at delivering cost savings and so‘… any new set of rules that simplify the tax treatment of T&S expenses must not overall come at a cost to the exchequer…’ consideration needs to be given to the impact on the cost of delivering essential public services.

The ‘cost of working’ should not increase for the employee, as a result of change for simplification, particularly if the changes are not initially perceived as achieving this outcome.

The CIPP look forward to being further involved with discussion and debate. And to this end watch out for news of upcoming Think Tank roundtable forums in January 2016.

Thank you to those of you who could give the time to feed in to this survey – following a busy year for consultations and surveys the policy team appreciated this enormously.