Skip to main content

Language: English / Gàidhlig

Loading…
Chamber and committees

Justice 2 Committee, 04 Mar 2003

Meeting date: Tuesday, March 4, 2003


Contents


Subordinate Legislation


General Commissioners of Income Tax (Expenses) (Scotland) Regulations 2003 (Draft)

I welcome Jim Wallace, the Deputy First Minister and Minister for Justice, and his officials. Members have a background note on the affirmative instrument that is next on the agenda. I invite the minister to speak to motion S1M-3930.

The Deputy First Minister and Minister for Justice (Mr Jim Wallace):

I will explain the background before I go into the detail of the regulations.

The general commissioners of income tax—who are unpaid lay volunteers—expressed concerns about their potential liability for costs and expenses in relation to legal proceedings that might arise from the execution of their duties. In response, the United Kingdom Government agreed to insert immunity and indemnity provisions into the Taxes Management Act 1970 and provisions were made for that in the Access to Justice Act 1999. Those provisions have now been commenced and cross-regulations made in respect of England, Wales and Northern Ireland.

However, before similar arrangements could be made in Scotland, it was necessary to seek executive devolution of the power to commence the provisions and to make associated regulations. The Scotland Act 1998 (Transfer of Functions to the Scottish Ministers etc) Order 2003 has been considered by the Scottish Parliament and by Westminster. It was approved by the Privy Council on 27 February and came into force on 28 February. The way is therefore clear for the Scottish ministers to commence the immunity and indemnity provisions in Scotland and, subject to commencement, to make the regulations that are before the committee today.

A commencement order that is not subject to parliamentary procedure has now been made, and will come into force on 31 March. However, the associated regulations that are before the committee today are subject to affirmative resolution and had to be laid in draft last month in order to ensure that they will come into force before Parliament is dissolved. It is desirable to have the regulations made soon after the new provisions are in place, not least because similar regulations have been in place for some time in the rest of the UK.

Once the immunity and indemnity provisions have commenced, the Taxes Management Act 1970 will provide a general rule that an order to pay expenses cannot be made against a general commissioner in any proceedings in respect of an act, or omission in execution or purported execution, of his or her duty. Exceptions to that general rule are made for proceedings in which a general commissioner is being tried for an offence, or appealing against a conviction, or where it is proven that he or she has acted in bad faith. The act will also permit a court, in proceedings in which an order to pay expenses cannot be made against a general commissioner, instead to make an order against the Scottish ministers.

The regulations set out how the amount of any payment by the Scottish ministers is determined and the circumstances in which an order for payment can be made. Regulation 4 provides that if an order is made, it shall provide compensation for expenses that are reasonably incurred by the person concerned. Regulation 5 precludes the making of an order against a public authority. To put the matter in context, I must say that I am not aware of an order for expenses ever having been made against a general commissioner. Nevertheless, the new provisions will contribute to removing the risk, however remote, of any such liability. I therefore invite the committee to approve the regulations.

You have just answered the question I was about to ask—this is a precaution.

Stewart Stevenson:

I get the firm impression that this is a bit of tidying-up that relates to history. Since the regulations derive from the 1970 act, they clearly precede the resumption of the Scottish Parliament by many years. Does the instrument relate to all the commissioners' work? In other words, does it concern the income tax system in general, rather than being restricted to that part of it which falls within the purview of the Scottish Parliament?

Mr Wallace:

Mr Stevenson is correct. Although the instrument relates to the 1970 legislation, an amendment was made to the 1970 legislation by the Access to Justice Act 1999. The power to commence the provisions in the 1999 act lies primarily with the Lord Chancellor. However, given that the Scottish ministers appoint the general commissioners in Scotland, it was decided to seek executive devolution of the commencement function. The role of the commissioners is as a tribunal that hears appeals against decisions that are made by the Inland Revenue on a variety of tax-related matters. Therefore, their role goes well beyond decisions that relate purely to the tax-varying powers of the Scottish Parliament.

Stewart Stevenson:

The minister will know that I have no objection at all to ministers in this Parliament taking on additional powers. However, in this case, it appears that the powers that we are taking on are in relation to the misuse of a responsibility that lies not with us but with others. The Scottish ministers' responsibilities related purely to the appointment of the individuals, but the exercise of those individuals' functions is over an area that is absolutely nothing to do with the Scottish Parliament. It is curious that we should pick up the tab for matters that are related to income tax, but which are not the responsibility of the Scottish Parliament.

Mr Wallace:

Indeed, the Scottish Parliament does not have powers relating to taxation other than the powers of variation. However, the matter is not strictly to do with income tax; rather, it is to do with the manner in which the commissioners who are appointed by the Scottish ministers perform their duties as a tribunal. In that respect, therefore, there is a difference. On that basis, we seek to commence the provisions to bring us into line with other parts of the UK.

In other words, you hold that the matter relates to what is very broadly a part of our justice system, and to a court that is interpreting and administering law in general—as indeed the civil and criminal courts more usually do.

I use the word "tribunal" rather than "court". You used the phrase "pick up the tab". No tab has ever been picked up, as far as we are aware, but there might always be a first time.

That gave us a helpful understanding of the matter. The commissioners are appointed by you—

They are appointed by the Scottish ministers.

In effect, their decisions are the cause of legal proceedings for which expenses will be paid—

Expenses will be paid for legal proceedings due to poor performance other than acting in bad faith or anything that might lead to criminal conviction.

I await with bated breath the impact of the legislation.

I hope that the regulations will never be put to the test. However, the request came from the general commissioners themselves, who felt that they needed the additional protection.

Thank you.

Motion moved,

That the Justice 2 Committee, in consideration of the draft General Commissioners of Income Tax (Expenses) (Scotland) Regulations 2003, recommends that the Regulations be approved.—[Mr Jim Wallace.]

Motion agreed to.


Regulation of Investigatory Powers (Prescription of Offices and Positions) (Scotland) Amendment (No 2) Order 2003 (SSI 2003/50)

The Convener:

Let us move on to item 4. I refer members to the letter from the Deputy Minister for Justice, Hugh Henry. The order was considered by the committee on 18 February, and several points were raised. Supplementary information was supplied by the Executive on one of those points, regarding the level of officers who will have the power. The agenda item allows members to return to the order and to satisfy themselves that the letter contains the answer that they were looking for. Before we begin, however, I point out that the Minister for Justice is not here to speak to the order.

Stewart Stevenson:

As helpful as the Deputy Minister for Justice's letter undoubtedly is in relation to the discussion that we had, it does not—unless I have failed to read it properly—address the point that I raised with the deputy minister in that discussion. My point was that the order, as I read it, will allow an inspector to renew an authorisation. As I said previously, I have no objection to that, but the minister appeared to think that that was not the policy intention. The letter does not address the discrepancy between the wording of the order and the policy intention on renewals.

I do not wish to oppose or prevent the progression of the order, but I am uncertain about the issue of inspectors. The order appears to permit inspectors, when they have granted an authorisation as a matter of urgency or emergency, to renew the authorisation. That is contrary to the deputy minister's stated policy aim that such authorisations should take place at the normal level.

The Convener:

Members will recall that, at the previous meeting, we dealt with two affirmative instruments and one negative instrument, all of which relate to the Regulation of Investigatory Powers (Scotland) Act 2000. I wrote to Hugh Henry on the committee's behalf on a matter that related to the negative instrument.

Perhaps I am confused.

The Convener:

The matter is confusing. The committee and the report from the Subordinate Legislation Committee, which is where the issue began, raised the specific point about which officers of lower rank are covered by the order that we are considering. The letter that we have received from the deputy minister clarifies that point. If there are other points about the two affirmative instruments we can, for tidiness, write to the Executive about them.

The whole matter is pretty confusing. We dealt with the original legislation in 2000 and three years later we were asked to agree to two codes of practice, which were introduced as two instruments that were subject to the affirmative procedure and one that was subject to negative procedure. Members will recall that we have dealt with other instruments that relate to the 2000 act. It is confusing for Parliament for so many instruments to appear in relation to important legislation. Therefore, I have asked for a note to be prepared for Parliament so that when it votes on the instruments members are clear about from where the instruments derive, and whether they are subject to the affirmative or negative procedure. Such a note is not normally prepared, but I have asked for one.

If Stewart Stevenson feels that there is a need to clarify points further, I will be happy to write to the Executive.

Stewart Stevenson:

I am content with the order and I do not feel compelled to push the matter. However, at the previous meeting, we were left in a somewhat unsatisfactory state because the minister could not persuade himself that I was wrong—I think that that is the correct way of describing the situation. My interpretation of the order appeared to be at odds with the policy objective. In any event, I am content and I do not feel the need to push the matter. In the interests of not confusing the minister or members any further, I am happy to let the matter lie.

Bill Aitken:

It would be eminently sensible to have a note—such as that which the convener suggested—when the instruments go before Parliament; the matter has not been dealt with terribly happily. Although I am satisfied that there is absolutely no intention of malfeasance on the part of the Executive—far from it—there are lessons to be learned about making such matters clearer.

The Convener:

We have learned lessons about the committee's requirements in dealing with complicated instruments that are produced a long time after the original legislation. In such cases, we require more discussion and explanatory notes, although I hope that we will put that right in this case. When Parliament votes on the instruments, it should have a note from the committee that makes the instruments easier to understand.