Re: [tax] Have a look at the positionpaper and send finalcomments to be included in the paper

[Andy Greener <andy@gid.co.uk>]

At 10:20 pm +0200 20/5/04, Harm-Jan van Burg wrote:
>Send in comments via the list so that others can read them as well and react
>if necessary.
>To be able to include comments timely closure time is 6 pm eastern at
>Tuesday 24.

On the assumption that Harm meant Tuesday *25th*, I hope I'm not too late...

Some specific comments on v0.5 of the paper:

1. Section 1.2 Decisions: Since we're going to be discussing technical
standards such as web services and ebXML in Washington to determine if
we want to cover them in v2 of the Position Paper it is a little premature
to be declaring them out of scope. I suggest we just drop the last sentence
of the first paragraph for now.

2. Section 2.2.2 Existing State of Information Exchange: This section
paints an altogether too negative view of the current state, at least as
far as the UK is concerned - we have interactive services covering both
large and small submitters, corporate and individual, with a high degree
of uniformity at least at the enveloping level. A description of a range
of abilities across administrations might be more appropriate here.

3. Section 3.1 XML Overview: Where 'XML document' is mentioned I would
make this explicitly 'XML instance document' for clarity.

4. Section 3.2 Why further XML standards?: I think we've determined that
CAM should be removed from this document, and therefore from this section.
Also, I would move CICA from the tax-specific content standards to the
business document exchange section, and duplicate OAGIS there too. Both
OAGIS and UBL include standard (indirect) tax components but CICA is too
general. However all three provide standards for business document
structuring, and therefore 'exchange' (which might be less ambiguously
described as 'interoperability' here).

5. Section 3.3 Standards Coverage: Again, remove the sentence eliminating
web services and ebXML from scope (as per 1 above).

6. Section 4.1 XBRL: The examples quoted in the opening sentence are too
Oz-centric :-) It might be better to stick with generic terms such as
P&L account and balance sheet (they are generic aren't they?!)

7. Section 4.1 XBRL: The opening para still doesn't make a proper distinction
between XBRL as a technical standard for financial/business reporting and
the characteristics of particular local Taxonomies - the quoted examples of
financial items are presumably present in the Australian GAAP Taxonomy,
but not necessarily in anyone else's, and the "missing" ones would not
necessarily be needed elsewhere.

8. Section 4.1 Committee Recommendations: These recommendations are
directed at the Tax XML TC, whereas the audience for this paper is the
tax administrations themselves. Either the title needs to change or the
recommendations (or 'emerging directions' as JG puts it) we're making to
the administrations need to be enumerated here instead. Perhaps it is
appropriate to have both Recommendations (to Administrations) and Actions
(for the TC), so that administrations can see what we're doing/intending
to do?

9. Section 4.2/4.3 UBL/OAGIS: It may be worth mentioning that both UBL
and OAGIS already include standard components for indirect taxation in
their existing coverage of "supply chain" document standards, since this
is of direct relevance to administrations involved in indirect taxation.

10. Section 4.2 Committee Recommendation: Again, these are not aimed at the
audience for the Paper but at the TC itself.

11. Remove section 4.4 CAM.

12. Section 4.5 CICA: Note the first 'C' in CICA stands for Context not
Component.

13. Section 4.7 SAF: I think some more work is needed here to bring
XBRL GL into the picture.

	Andy
-- 

Andy Greener                         Mob: +44 7836 331933
GID Ltd, Reading, UK                 Tel: +44 118 956 1248
andy@gid.co.uk                       Fax: +44 118 958 9005