Consultation outcome

Harnessing the potential of the UK’s natural resources: a fiscal regime for shale gas

Updated 10 December 2013

This was published under the 2010 to 2015 Conservative and Liberal Democrat coalition government

0.1 Preface

Subject of this consultation	Introducing proposals for the tax regime for shale gas.
Scope of this consultation	This consultation seeks views on the government’s proposals for a shale gas pad allowance and an approach to deliver the extension of the Ring Fence Expenditure Supplement for shale gas projects.
Who should read this	The government would like to hear from a wide range of stakeholders including individuals, companies, communities and representative and professional bodies. In particular, the government invites comments from companies involved in exploration for, and production of, oil and gas in the UK and on the UK Continental Shelf, including those involved in the provision of financial and legal services.
Lead officials	Nico Heslop, Environment and Transport Taxes Team, HM Treasury; Laura Kiddoo, Environment and Transport Taxes Team, HM Treasury
Additional ways to be involved	As part of the consultation process, we would like to establish a working group of tax and finance experts to discuss technical issues raised by the consultation. If you would like to be a working group member please send a nomination, with your current position and organisation, using these correspondence details.
After the consultation	The government will publish a summary of responses to this consultation later in the year. Where appropriate, legislation will be brought forward in Finance Bill 2014.
Getting to this stage	This consultation follows an announcement at Budget 2013 that the government would introduce a new allowance for shale gas and extend the Ring Fence Expenditure Supplement for shale gas projects from six to ten accounting periods.
Previous engagement	An informal consultation was held with industry at the end of 2012 and the government has held discussions with the industry since Budget 2013. This engagement has helped to inform development of the proposals set out in this consultation document.

0.2 Foreword

Shale gas has the potential to transform our future energy supply and bring significant economic benefits. It could increase our energy security, support thousands of jobs and generate substantial tax revenue for the nation. It would be irresponsible of government not to do everything it can to support the safe and sustainable development of shale gas.

The British Geological Survey’s recent report highlighted the UK’s significant shale gas resources - more than twice as much in the north of England than we previously thought existed across the entire country. But industry will now need to determine how much of this is recoverable. We are committed to helping unlock the investment needed by putting the right fiscal and regulatory framework in place. This will build on the UK’s history of safely and sustainably extracting oil and gas onshore.

Budget 2013 announced a package of measures on tax, planning and community benefits to help kick-start exploration. Last month, an industry-led scheme was published to make sure communities share in the benefits of shale gas developments in their areas, and the Environment Agency produced a plan for streamlining and simplifying the permitting process.

This consultation outlines the proposed tax regime for shale gas to drive early investment. The generous regime would support the industry in its early stages when costs are likely to be higher and risks of unsuccessful exploration are greater. It aims to ensure that industry can continue to match the government’s ambition in this important sector.

Shale gas is an exciting new resource with huge potential to revolutionise our future energy mix. The tax incentives proposed in this consultation are part of a comprehensive package to make sure the government provides the right conditions for industry to fully explore this potential.

Sajid Javid

Economic Secretary to the Treasury

July 2013

1. Introduction

At Budget 2013, the government announced a package of measures designed to incentivise investment and support the development of the UK’s shale gas industry. This package included the introduction of a new tax allowance and the extension of the Ring Fence Expenditure Supplement for shale gas projects from six to ten accounting periods.

1.1 Structure of the document

The remainder of the document is set out as follows:

• Chapter 2 explains the background to these proposals
• Chapter 3 sets out the objectives for the tax regime for shale gas
• Chapter 4 outlines a proposal for a shale gas pad allowance
• Chapter 5 presents the government’s proposed approach to deliver the extension of the Ring Fence Expenditure Supplement
• Chapter 6 provides an assessment of the impacts of the fiscal incentives
• Chapter 7 summarises the consultation questions and explains the consultation process

1.2 Stage of consultation

The proposals set out in this document are at stage 1 (setting out objectives and identifying options) and stage 2 (determining the best option and developing a framework for implementation including detailed policy design) of the government’s framework for tax consultation.

2. Context

2.1 Shale gas

The UK shale gas industry is in its early stages, but extracting oil and gas onshore is not new. Over the last 30 years more than 2,000 wells have been drilled onshore in the UK and approximately 200 of these have been hydraulically fractured (or ‘fracked’). Western Europe’s largest onshore oil and gas field is in Dorset, at Wytch Farm. The UK’s significant experience of onshore oil and gas activity has meant that well established and robust regulatory and licensing regimes have developed, as with the offshore industry. These regimes would apply equally to shale gas projects.

Shale gas has significant potential to create jobs and generate substantial revenue for the Exchequer. It could also greatly increase our energy security – making us less dependent on imported gas supplies and reducing our exposure to geopolitical risks and lengthening supply chains. UK net gas imports are set to rise from 45 per cent of demand in 2011 to 76 per cent by 2030, according to the latest central projections from the Department of Energy and Climate Change. The cost of these imports is expected to increase from £5.9 billion to around £16 billion (in 2012 prices) over the same timeframe. It is therefore important that the government provides the right conditions to allow companies to explore fully the potential of domestic gas resources.

The scale of this potential was highlighted in a report published by the British Geological Survey (BGS) on 27 June 2013 which estimated that the total volume of gas ‘in place’ in the Bowland Hodder shale in the north of England is approximately 1,300 trillion cubic feet (central estimate). The BGS study is the first in the UK to provide investors, operators and regulators with an indication of where to target future exploratory drilling, which will be required to determine the extent of gas that can be technically and commercially recovered.

In the United States, shale gas has brought substantial economic benefits. In 2012 the US shale gas industry accounted for over 600,000 jobs and paid almost $20 billion in taxes. It has dramatically reduced the price of gas, improved the US balance of payments and reduced their dependence on gas imports.

It is not yet clear the extent to which the US experience can be replicated here. Technical differences in the nature of the gas resources, in geography and population patterns may all have an impact. But the government is committed to doing everything it can to create the long term conditions to incentivise investment and support the industry’s development – so that if companies determine that the geological and geographical conditions in the UK are right, they are not impeded by unnecessary barriers.

Experience in the US demonstrated that it is vital to get the overall fiscal and regulatory framework right. So, at Budget 2013, the government announced a package of measures designed to kick-start exploration of the UK’s shale gas resources. This included:

• a consultation on tax incentives to encourage exploration and to provide the industry with certainty on the long-term tax treatment of shale gas;
• new guidelines on the planning regime for shale gas to clarify the process
• an industry-led scheme to ensure communities benefit from hosting projects

Since Budget, the Environment Agency has announced plans to simplify and accelerate the permitting process for shale gas developments and the industry has come forward with a robust scheme to ensure local communities share in the benefits. Operators have committed to providing at least £100,000 per well-site where hydraulic fracturing occurs at exploration phase, and one per cent of revenues.

This consultation covers the tax strand of the shale gas package. It follows an informal consultation with companies at the end of 2012 which highlighted the importance of providing the industry with clarity around the long-term tax treatment of shale gas profits. Companies noted the slower cost recovery for shale gas projects than in conventional offshore fields and that shale gas developments require multiple investments, often across a much wider area than a traditional oil field – increasing ongoing cost and uncertainty. The information gathered during the informal consultation helped inform the development of the proposals outlined in this consultation – the introduction of a shale gas ‘pad allowance’ and the extension of the Ring Fence Expenditure Supplement.

2.2 Oil and gas taxation – the current regime

Profits from shale gas production would currently be subject to the ‘ring fence’ tax regime for oil and gas. The ring fence fiscal regime applies to the exploration for, and production of, oil and gas in the UK and UK Continental Shelf (UKCS) and comprises three taxes.

Ring Fence Corporation Tax (RFCT)	This is calculated in the same way as the mainstream corporation tax applicable to all companies but with the addition of a ‘ring fence’ and the availability of 100 per cent first year allowances for virtually all capital expenditure. The ring fence prevents taxable profits from oil and gas extraction in the UK and UKCS from being reduced by losses from other activities or by excessive interest payments. The current main rate of tax on ring fence profits, which is set separately from the rate of mainstream corporation tax, is 30 per cent.
Supplementary Charge (SC)	This is an additional charge, currently set at a rate of 32 per cent, on a company’s adjusted ring fence profits (which exclude finance costs).
Petroleum Revenue Tax (PRT)	This is a field-based tax charged on profits from oil and gas production from individual oil fields which were given development consent before 16 March 1993. The current rate of PRT is 50 per cent. PRT is deductible as an expense in computing profits chargeable to RFCT and SC.

The overall effect of the fiscal regime is a marginal tax rate of:

• 81 per cent on profits from PRT-paying fields
• 62 per cent for other fields

These rates are reduced on any portion of income covered by field allowances to 65 per cent (PRT-paying fields) and 30 per cent (other fields).

The aim of the oil and gas fiscal regime is to maximise the economic recovery of the UK’s oil and gas reserves and ensure a fair return for taxpayers. To help achieve this aim, the government provides support through field allowances for projects that are economic but commercially marginal given the current tax rates. Fields that qualify for allowances obtain relief on the 32 per cent supplementary charge for a certain amount of their production income. They still pay ring fence corporation tax on this portion.

The government also provides support for companies with ring fence losses, through the Ring Fence Expenditure Supplement (RFES). RFES allows companies in the ring fence to uplift their losses (or pre-trading expenditure) by 10 per cent for up to six accounting periods to maintain their time value until they can be offset against future profits. The aim of RFES is to help companies that do not have sufficient taxable income, typically at the start of a project, against which to set their costs and capital allowances.

Providing support for challenging onshore unconventional hydrocarbon projects is therefore consistent with the government’s approach under the existing regime.

3. The government’s objectives

Shale gas is a new industry which will require large and ongoing expenditure before profits are made. During the critical exploration phase, before the commercial viability of projects is established, companies will bear significant risk. Once production is established, shale gas projects are still likely to be subject to challenging economics compared to conventional developments – with high ongoing well intervention costs and longer payback periods. The government is therefore committed to supporting these projects, consistent with the approach taken with challenging offshore oil and gas fields.

The government will adopt an approach to support these projects that:

• encourages early investment in the exploration for, and development of, shale gas in the UK
• maximises the economic production of the UK’s shale gas reserves
• is flexible enough to adapt as the industry moves from the exploration phase to production, but stable enough to provide certainty for companies currently considering investment in the UK
• uses existing mechanisms for delivering relief as far as possible to avoid adding unnecessary complexity to the ring fence regime
• ensures a fair return for the taxpayer, is not open to abuse and is affordable, in line with the government’s objective for long term sustainability in the public finances

4. Pad allowance

At Budget 2013 the government announced that it would introduce a new allowance for shale gas projects to incentivise early investment and provide the industry with the certainty it needs on the tax treatment for shale gas. This chapter seeks the views of interested parties on a proposal to provide targeted support through a pad allowance.

4.1 Proposed approach

Conventional oil and gas reserves are found in discrete fields or reservoirs. In contrast, unconventional hydrocarbons cover large areas with indistinctly defined boundaries. As a result, it is difficult to identify an unconventional oil or gas field. Current allowances in the oil and gas fiscal regime are dependent on the existence of a clearly delineated field, so would not be appropriate for unconventional reserves. The government has therefore proposed an approach based at the pad level, where a pad is the term used to describe the drilling and extraction site.

The pad allowance would operate similarly to existing field allowances, by exempting a portion of production income from the supplementary charge – reducing the effective tax rate on that portion from 62 per cent to 30 per cent at current tax rates.

The amount of production income exempt from the supplementary charge would be a proportion of the capital expenditure incurred in relation to the shale gas pad. For the purposes of the pad allowance, capital expenditure would be limited to expenditure that would attract 100 per cent first year capital allowances.

Companies would start to generate and hold the allowance as soon as they incurred capital expenditure on a pad. Costs incurred prior to the effective date of the introduction of the pad allowance would not contribute to the generation of the allowance.

The amount of allowance activated (i.e. made available to offset against profits) in any accounting period would be no more than the amount of production income from the pad. Any activated allowance not used to reduce the supplementary charge otherwise payable by a company in a particular accounting period would be carried forward to the next.

Shale gas would remain within the UK upstream oil and gas tax ring fence, so companies would continue to benefit from first year allowances for capital expenditure and the Ring Fence Expenditure Supplement. The allowance, when activated, would be available to be used against all of a company’s adjusted ring fence profits i.e. it would not be restricted to set off against profits from shale gas production.

The government believes that this option recognises the high upfront costs associated with shale gas projects and ensures that the greatest support is offered to the industry in its early stages when costs per pad are likely to be highest. It also provides industry with certainty around how shale gas profits will be treated for tax purposes, to incentivise investment.

The government is committed to ensuring a fair return for the taxpayer and protecting the Exchequer. The current tax regime has in place measures to tackle abuse, and the government will take steps to ensure that the tax regime for shale gas does not create opportunities for tax avoidance or abuse.

Question 1	Would the proposed pad allowance achieve the objectives set out in chapter 3?
Question 2	Are there variations to the pad allowance option that would better meet the objectives outlined in chapter 3? If so, please provide evidence to support your case.
Question 3	Do you think there are any commercial models that are likely to be adopted that would be incompatible with the pad allowance?
Question 4	Do you agree that, for the purposes of the pad allowance, capital expenditure should cover expenditure that would attract 100 per cent first year capital allowances?
Question 5	Will the pad allowance introduce any additional administrative burdens for businesses, particularly the need to track expenditure on a pad-level? If so, are there options the government could consider to reduce this burden?
Question 6	Do you agree that current arrangements to protect the Exchequer are sufficiently robust for the pad allowance? Do you think there are any additional measures that would be helpful in this regard?

4.2 Level of allowance

This consultation document does not propose a specific proportion of capital expenditure that would set the level of the allowance. In setting this level the government will consider the objectives set out in chapter 3, in particular the need to incentivise early investment. This level may need to be higher during the industry’s exploration phase, when development risks are higher and costs are greater. Respondents are asked to provide information on the economics of shale gas projects to inform the government’s decision on the appropriate level.

Question 7

Can you provide evidence on the potential economics and commercial framework of shale gas projects? This could include (but is not limited to):

• the likely capital expenditure and operating expenditure profile of a shale gas project during both exploration and production phases
• the likely scale of the initial investment in both exploration and development phases, and the net profits companies are anticipating
• how many years after first investment companies expect production to start
• what (range of) recovery rates companies have assumed in their economic analysis
• whether companies plan to be involved in both the exploration and development phases of shale gas
• how many pads companies expect to develop over the next five years
• whether companies expect to have other ring fence profits during the initial exploration phase before their shale gas activities become profitable

4.3 Scope

The Budget announcement committed to consulting on extending the scope of the allowance beyond shale gas. There are similarities between shale gas projects and other onshore unconventional hydrocarbon projects, including cost characteristics, project timescales, payback periods and risk profiles. Given these similarities, the government proposes to extend the scope of the pad allowance to all onshore unconventional hydrocarbons, using the definition below.

Unconventional hydrocarbons – proposed definition

An extensive and continuous occurrence of petroleum which has not migrated from its source rock and is not significantly affected by hydrodynamic influence

If the pad allowance is extended to all onshore unconventional hydrocarbon projects, the government would propose removing the eligibility of these projects from all other field allowances. Existing fields which already qualify for an allowance, however, would retain their eligibility for that allowance and would not qualify for the pad allowance.

While the government proposes to extend the pad allowance to all onshore unconventional hydrocarbons, it would also welcome views and supporting evidence on extending the pad allowance to all onshore hydrocarbon developments.

To simplify the onshore regime, if the pad allowance were to be introduced for all onshore hydrocarbon projects, the government would propose to remove the eligibility of onshore projects from all other field allowances. The pad allowance would become the only allowance for onshore activities.

The costs of offshore drilling and production operations are many times those of onshore operations, so exploration for shale gas or oil offshore is much less likely to be attractive commercially in the short-term. To date there has not been any offshore exploration for shale gas or oil anywhere in the world. However, the government thinks it is prudent to keep developments offshore under review and would welcome views on the impact of the tax regime on the longer-term potential for offshore production of shale gas or oil.

Question 8	Do you agree with the government’s proposed approach of extending the pad allowance to cover all onshore unconventional hydrocarbons?
Question 9	Do you agree with the proposed definition of unconventional hydrocarbons?
Question 10	Do you think there is a case for extending the allowance to all onshore hydrocarbon projects? If so, please provide evidence to support your case. Could there be risks associated with this option?
Question 11	If the allowance was extended to all onshore unconventional hydrocarbons, or to all onshore hydrocarbons, do you think there are any potential risks or unintended consequences of removing these projects from the scope of all current field allowances and instead providing the projects with the proposed pad allowance?
Question 12	Do you have views on the impact of the tax regime on the longer-term potential for offshore shale gas or oil production?

4.4 Timing

The quickest that existing field allowances can be used fully is over five years, with a maximum of 20 per cent of the total allowance activated each year. Given the possibly steep production decline rates from shale gas (as evidenced by projects in the US), this timeframe may not be appropriate for the pad allowance.

Question 13

Do you think that the five-year minimum activation period, which is a feature of existing field allowances, is appropriate for the pad allowance given the objectives set out in chapter 3? If not, can you provide evidence in support of an alternative rate of access to the allowance?

4.5 Split between participants

Existing field allowances for new fields are divided between participants in a field in proportion to each company’s share of equity in the field. Given the structure of the pad allowance, the government proposes that each participant in a pad would generate their own allowance based on the capital expenditure they incur. Under this approach, a participant in a pad that did not incur any capital expenditure would not be entitled to any allowance.

Question 14

Do you agree that the allowance should be split between participants in a pad based on actual expenditure incurred by each participator? If not, what do you consider to be a more appropriate method to split the allowance between participants?

5. Ring Fence Expenditure Supplement

At Budget 2013, the government committed to extend the Ring Fence Expenditure Supplement (RFES) for shale gas projects from six to ten accounting periods. This change was designed to recognise the longer payback period for shale gas projects. Steep production decline rates are expected to mean that high and continuous investment is required in wells, extending the period of investment over a longer timeframe than conventional projects. The extension of RFES will allow companies without existing ring fence profits to maintain the time value of their losses over this longer payback period.

Given the similarities in cost and timing for shale gas and other onshore unconventional hydrocarbon projects, the government proposes to extend RFES from six to ten accounting periods for all of these projects, using the definition set out in section 4.3.

To ensure that all onshore unconventional hydrocarbon losses or pre-trading expenditure can be uplifted for the full ten accounting periods, it will be necessary for companies at the end of their sixth period to disaggregate losses from these projects from their total loss pool. The non-onshore unconventional loss pool would not be eligible for further RFES claims.

A company would be able to claim RFES for the additional four periods if it is in loss and some of that loss has been generated by onshore unconventional hydrocarbon activity. The amount of the loss generated by this activity would be available to receive the further RFES uplift. The entire loss pool would be available to set off against all ring fence profits.

Question 15	Will companies be able to disaggregate their onshore unconventional hydrocarbon losses from wider company losses in order to make the further four RFES claims? Would doing so pose a disproportionate administrative burden?
Question 16	Are there alternative approaches the government could consider for the administration of the extension of the Ring Fence Expenditure Supplement for onshore unconventional hydrocarbon projects?
Question 17	Do you agree that the extension of RFES should apply to all onshore unconventional hydrocarbon projects, using the definition set out in section 4.3?

6. Summary of impacts

The following is a consultation stage Tax Impact Assessment of the impact of providing fiscal incentives for shale gas development. We welcome any comments on our assessment of the impacts. These will feed into the Tax Information and Impact Note to be published alongside draft legislation in the autumn.

Exchequer impact	Since this consultation document does not propose a specific level of allowance, it is not currently possible to estimate the Exchequer impact. The government will be using data gathered through the consultation to determine the appropriate level of allowance to achieve the government’s objectives, particularly to incentivise investment, and to identify the Exchequer impact. This information will also be used to estimate the impact of the extension to the Ring Fence Expenditure Supplement, where we do not currently have the necessary data to provide a reliable estimate.
Economic impact	The proposals outlined are expected to increase investment in shale gas exploration. If exploration establishes the commercial viability of the UK’s shale gas resources, then there could be a significant increase in the production of hydrocarbons, the creation of jobs, increased energy security and benefits to the UK supply chain.
Impact on individuals and households	Any resulting increase in production would contribute to the UK’s security of energy supply and has the potential to keep energy bills lower than they might otherwise have been.
Equalities impacts	The proposals are considered to have no differential impact on any equality groups.
Impact on businesses and Civil Society organisations	The proposals are designed to support the industry through the exploration phase by relieving a portion of their income from the supplementary charge. The allowance is expected to incentivise early investment in shale gas exploration. The administrative impacts on companies from the proposals are anticipated to be negligible, but the consultation seeks views on this.
Impact on HMRC or other public sector delivery organisations	The additional costs for HMRC in implementing these proposals are anticipated to be negligible.
Other impacts
Sustainable development, wider environment and health	While the changes are expected to increase exploration activity, the UK has a strong regulatory system which provides a comprehensive and fit for purpose regime for exploratory activities. The Office for Unconventional Gas and Oil, within DECC, will continue to work closely with regulators and industry to ensure that the regulatory process remains robust to safeguard public safety and protect the environment.
Small firms impact	The administrative impacts on small companies are expected to be negligible. The extension of the Ring Fence Expenditure Supplement will allow smaller firms with no existing ring fence profits to uplift their losses and pre-trading expenditure by a further four accounting periods.

7. Consultation process

The government welcomes views on the following questions:

Question 1	Would the proposed pad allowance achieve the objectives set out in chapter 3?
Question 2	Are there variations to the pad allowance option that would better meet the objectives outlined in chapter 3? If so, please provide evidence to support your case.
Question 3	Do you think there are any commercial models that are likely to be adopted that would be incompatible with the pad allowance?
Question 4	Do you agree that, for the purposes of the pad allowance, capital expenditure should cover expenditure that would attract 100 per cent first year capital allowances?
Question 5	Will the pad allowance introduce any additional administrative burdens for businesses, particularly the need to track expenditure on a pad-level? If so, are there options the government could consider to reduce this burden?
Question 6	Do you agree that current arrangements to protect the Exchequer are sufficiently robust for the pad allowance? Do you think there are any additional measures that would be helpful in this regard?
Question 7	Can you provide evidence on the potential economics and commercial framework of shale gas projects? This could include (but is not limited to):

• the likely capital expenditure and operating expenditure profile of a shale gas project during both exploration and production phases
• the likely scale of the initial investment in both exploration and development phases, and the net profits companies are anticipating
• how many years after first investment companies expect production to start
• what (range of) recovery rates companies have assumed in their economic analysis
• whether companies plan to be involved in both the exploration and development phases of shale gas
• how many pads companies expect to develop over the next five years
• whether companies expect to have other ring fence profits during the initial exploration phase before their shale gas activities become profitable

Question 8	Do you agree with the government’s proposed approach of extending the pad allowance to cover all onshore unconventional hydrocarbons?
Question 9	Do you agree with the proposed definition of unconventional hydrocarbons?
Question 10	Do you think there is a case for extending the allowance to all onshore hydrocarbon projects? If so, please provide evidence to support your case. Might there be risks associated with this option?
Question 11	If the allowance was extended to all onshore unconventional hydrocarbons, or to all onshore hydrocarbons, do you think there are any potential risks or unintended consequences of removing these projects from the scope of all current field allowances and instead providing the projects with the proposed pad allowance?
Question 12	Do you have views on the impact of the tax regime on the longer-term potential for offshore shale gas or oil production?
Question 13	Do you think that the five-year minimum activation period, which is a feature of existing field allowances, is appropriate for the pad allowance given the objectives set out in chapter 3? If not, can you provide evidence in support of an alternative rate of access to the allowance?
Question 14	Do you agree that the allowance should be split between participants in a pad based on actual expenditure incurred by each participator? If not, what do you consider to be a more appropriate method to split the allowance between participants?
Question 15	Will companies be able to disaggregate their onshore unconventional hydrocarbon losses from wider company losses in order to make the further four RFES claims? Would doing so pose a disproportionate administrative burden?
Question 16	Are there alternative approaches the government could consider for the administration of the extension of the Ring Fence Expenditure Supplement for onshore unconventional hydrocarbon projects?
Question 17	Do you agree that the extension of RFES should apply to all onshore unconventional hydrocarbon projects, using the definition set out in section 4.3?

7.1 Confidentiality

Information provided in response to this consultation, including personal information, may be published or disclosed in accordance with the access to information regimes. These are primarily the Freedom of Information Act 2000 (FOIA), the Data Protection Act 1988 (DPA) and the Environmental Information Regulations 2004.

If you want the information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals with, amongst other things, obligations of confidence. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on HM Treasury.

HM Treasury will process your personal data in accordance with the DPA and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

7.2 Consultation principles

This consultation is being run in accordance with the government’s Consultation Principles.

If you have any comments or complaints about the consultation process please contact:

Amy Burgess
Consultation Coordinator
Budget Team
HM Revenue & Customs
100 Parliament Street
London
SW1A 2BQ

Or email hmrc-consultation.co-ordinator@hmrc.gsi.gov.uk

Please do not send responses to the consultation to this address.