ACCA is responding to a consultation by Revenue Scotland for a digital shake-up and overhaul of how it communicates with taxpayers. Revenue Scotland is the independent tax authority responsible for the administration and collection of devolved taxes in Scotland. The organisation wants to move to a ‘digital by default’ approach to communications.

ACCA has thrown its support behind the strategic direction, while setting out a series of conditions it believes must be met before the changes are introduced.

Susan Love, ACCA’s head of policy for Scotland, said: “Scotland’s tax system needs to move with the times and we support Revenue Scotland’s ambition to modernise its communications. But digital first must not become digital only. 

“Across Scotland - from the islands to rural communities - there are areas where broadband connectivity remains unreliable. Any new framework must be built around the needs of all taxpayers - those who interact with Revenue Scotland now and those who may do in the future. So, we need to make sure going online is as straightforward as possible. We need robust safeguards, clear opt-out processes, and a system that doesn’t inadvertently shut people out of their own tax affairs.”

Central to ACCA’s response is a call for Revenue Scotland to make explicit provision for professional agents - the accountants and tax advisers - who manage the affairs of thousands of Scottish businesses and individuals.

The body warns that the reforms risk creating confusion and compliance failures, if there are no clear mechanisms to ensure agents receive the same information as their clients. ACCA says the taxpayers’ right to professional representation needs to be properly embedded.

ACCA has a significant presence in Scotland, with around 11,000 members and students across the country, and more than 600 employees based at its global operations centre in Glasgow.

Christian Novak, ACCA policy manager, EEMA and UK, said: “Many taxpayers won’t currently be interacting with Revenue Scotland directly given its limited responsibilities. With Revenue Scotland only established in 2015, the system must be future-proofed to handle both remit changes and a widening tax base. The transition should not be based solely on the needs of sophisticated taxpayers and their professional advisers.”

ACCA’s response draws on the transformation journeys of other jurisdictions, including that of the Inland Revenue Department (IRD) in New Zealand. The body believes the IRD’s customer-first focus, phased implementation, and tailored stakeholder engagement can help guide Revenue Scotland’s thinking.

ACCA is also recommending that Revenue Scotland updates its Charter of Standards and Values to include a standalone section on professional agents, and ensure its principles align with good practice before the new system goes live.