Tax Agent Population Research DWP/HMRC Social and Economic Research Services – Procurement Framework Invitation to Tender Knowledge, Analysis and Intelligence Bush House, S.W. Wing, South Spur, 4th Floor, Strand, London, WC2B 4RD Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 1 1. Introduction 1.1 HM Revenue and Customs (HMRC) wishes to commission a research project that will help HMRC to understand the attitudes, needs and behaviours of tax agents towards the use of digital services. 1.2 Agents are a key customer group for the Department, helping individuals and businesses to comply with tax obligations. It is estimated that there around 43,000 paid agents operating in the UK who represent 8 million customers. 1.3 The Department is seeking to encourage greater use of digital services among the tax agent community in keeping with the digital strategy published in 20121. The Department is keen to understand how the agent community is likely to respond to the increasing use of digital services, and what support and incentives might be useful for helping agents to make the transition to digital. 1.4 The research will segment the agent population according to their use of digital services and level of support they will need to make the transition to digital. The research will therefore need to include both a quantitative survey of a sample of the agent population and qualitative fieldwork to test the validity of the segmentation. It is envisaged that fieldwork will commence in March 2014. 1.5 The research will also update the Department’s knowledge about the agent community following the completion of research which was published in 20092. Summary of key requirements 1.6 The project will include a survey of 1,700 agents and qualitative research with a sub-sample of these respondents. In the short term, the development work for the survey and fieldwork are expected to take place as soon as possible, with ideally around two-thirds of the fieldwork completed by the end of the 2013/14 financial year. The segmentation analysis and qualitative fieldwork are expected to take place early in the 2014/15 financial year, and reporting to take place in the summer of 2014. 2. Policy background 2.1 HMRC plays a pivotal role in UK society as the tax administration and collection body. This includes facilitating the collection of the right amount of taxes from customers for the Exchequer from which to fund delivery of government objectives. 2.2 HMRC regularly reviews different options to facilitate customers’ engagement with HMRC and to help them pay the right amount of tax while achieving value for money for the taxpayer in terms of the Department’s operating costs. HMRC’s digital strategy aims to help customers engage with HMRC in a simpler way, reducing customer burden. 1 The digital strategy can be accessed at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/89244/2012digital-strategy.pdf 2 The results of this research are reported at: http://www.hmrc.gov.uk/research/report120.pdf Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 2 The role of agents and digital services 2.3 HMRC wants to support agents and make it as straightforward as possible for them to fulfil their client’s tax obligations. In order to facilitate this, HMRC are introducing new digital services to a small number of agents in autumn 2014 followed by a gradual release to the wider agent population. HMRC digital services offering aims to: 3. help agents take more control of their clients' tax affairs let agents carry out the same tasks online as their clients reduce the need for agents to contact HMRC make the information about client tax affairs more accurate and up-to-date reduce costs to both agents and HMRC Project Aims and Research Questions Aims 3.1 The primary aim of the research is to provide a demographic segmentation of the population of paid (professional) tax agents according to their use of digital services, their needs and the support they will require to make the transition to digital. The segmentation would ideally be such that HMRC can identify agents in different segments using data held by the Department. However, the segmentation may make use of additional factors which are not identifiable on HMRC systems if this improves the quality of the analysis. 3.2 A secondary aim of the project is to explore the ways in which HMRC can facilitate agent’s transition to digital, and explore how digital services will influence the operation of the agent market and client-agent relationships. 3.3 Finally, the project will update the Department’s knowledge about the paid agent community by profiling the agent population in terms of geodemographic variables developed via research published in 2009 (see paragraph 1.5). Research Questions 3.4 The key research question is ‘How do paid tax agents’ behaviours, skills and attitudes influence their readiness for the transition to digital services”? 3.5 The project will address the overall research question by considering the following sub-questions, which are listed in order of priority: What geo-demographic segments of the agent population are more ready (in terms of attitudes and capabilities) to use HMRC’s digital services and what segments are less ready? What are the barriers and enablers for agents seeking to use digital services? How can HMRC help different segments of the agent population make the transition to digital? How do agents access information about HMRC and what role do digital services play? How will digital services influence agents’ contact with HMRC? How will digital services influence agent-client relationships? Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 3 What impact will the increasing use of digital services have on the agent market and how agents compete for custom? 3.6 HMRC invite bidders to suggest research designs which will address both the primary and secondary aims of the project, as described above. 4. Basic Design Background 4.1 In order to segment the population of paid agents according to their ‘readiness’ for digital services it is envisaged that a mixture of quantitative and qualitative research methods will be used. The qualitative component of the research will also be important for addressing the secondary aims of the research. Questionnaire development 4.2 In 2008, HMRC commissioned ICM to carry out quantitative research to improve the Department’s understanding of the paid agent community3. The successful tenderer will produce a new questionnaire which may utilise questions developed for the 2009 survey alongside new bespoke questions. 4.3 Because of the tight timescales for this research, there is not the capacity to cognitively test new survey questions. Bidders should bear this in mind when developing the new questionnaire. Survey piloting 4.5 HMRC would like the research to include a small scale pilot to test the administration of survey instruments, questionnaire design and interview length. We appreciate the tight timescales for this project, and welcome ideas for piloting. 4.6 If the pilot is successful and there are no changes to the questionnaire, the resulting data could contribute towards the target number of interviews required for the main survey if contractors can demonstrate this will not compromise the sample design. Sample 4.5 The preferred option is for the sample of agents to be drawn from HMRC’s administrative databases. It will be a random probability sample of the agent population, stratified in order to ensure a sufficient number of smaller agents (sole traders and partnerships) which are of particular interest in order to facilitate sub-group analysis. At present, it is anticipated that roughly 3 times the number of desired respondents will be supplied, but this may increase. 4.6 It is unlikely that valid telephone numbers will be included for most of the sampled businesses. It may also be necessary to remove duplicate agent enterprises from the sample as it will be drawn from several sources. Costs for telephone matching and the removal of duplicate agents from the sample must therefore be provided by the contractor. 3 A report of this work is available at: http://www.hmrc.gov.uk/research/report120.pdf. Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 4 5. Quantitative fieldwork 5.1 Advance letter and recruitment approach - Letters will need to be sent to the respondents in advance, both to give potential respondents the choice of opting out of the research, and to provide an interview brief. Initial contact will be crucial for recruitment of survey respondents, and tenderers should include details on their proposed approach including the experience of interviewers, and details about briefing and debriefing processes. 5.2 Telephone interviews – Interviews would be expected to last around 20 minutes by CATI. Where the sampled agent is a larger business (as opposed to a sole trader) interviews should be with a person who can provide responses on behalf of their business (e.g. director or senior manager). 5.3 The survey will need to include screener questions to ensure that the sampled business is acting as a paid agent. 5.4 HMRC propose that the survey achieve responses from around 1,700 agents to facilitate the segmentation analysis. However, we are open to suggestions about the appropriate number of respondents given the aims of the research. Bidders are therefore asked to propose recommended and minimal designs for the survey. 5.5 HMRC propose that the survey will achieve a large number of interviews in a relatively short period of time (see Table 1, 10.1 for project timetable). Tenderers should illustrate that they have the capacity to deliver the research in a timely way and that they have a fully trained and experienced field force able to conduct interviews with businesses. Bidders are also welcome to highlight any risks associated with this approach to data collection and how these would be mitigated. Further, bidders are welcome to propose alternatives either in terms of number of interviews or the fieldwork timetable in order to ensure the project achieves its aims and objectives. 5.6 Survey response rate - It is important that a high response rate is achieved for the survey. Bidders are asked to provide their best case; most likely and worst case scenarios for response rates and the implications of each of these on achieved sample sizes. As a guide, our desired response rate is 50% or more. 5.7 Bidders are expected to provide a detailed description of their proposals to encourage a high response rate. This includes the initial approach to agents and re-assurances about confidentiality and anonymity. 5.8 Data processing - Bidders are expected to use Computerised Assisted Telephone Interviews (CATI) technology to capture data for the main fieldwork and should outline their approach to editing and processing the data. Bidders who are proposing to apply data imputation approaches should describe their proposal in detail. 6. Data Analysis and Weighting 6.1 Segmentation analysis - The primary purpose of the research is to segment the population of agents according to their appetite and readiness for digital. The segmentation should be based on demographic information in order to Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 5 allow HMRC to identify which segment agents are likely to be in based on data held by the Department. 6.2 There are several possible ways of undertaking segmentation analyses. Bidders are invited to suggest an appropriate methodology and describe the advantages and disadvantages of the chosen approach. 6.3 Descriptive statistics - The research should also provide an up-to-date picture of what the population of agents looks like now, building on the research which was carried out in 2009. The successful contractor will be required to produce frequency tables for the key variables of interest, and include a discussion of these in the final report. 6.4 Tenderers will be expected to weight the results for this descriptive analysis in order to correct for survey non-response and stratification. Bidders are asked to demonstrate their ability to construct weights for analysis. 7. Qualitative interviews and focus groups 7.1 We are also interested in conducting qualitative research after the completion of the quantitative survey in order to test the validity of the segmentation analysis, address the secondary aims of the project and provide rich data for case studies. We envisage that a mixture of in-depth interviews and focus groups will be useful for these purposes, but we invite bidders to make suggestions about research design and methodology in order to achieve the project aims. 7.2 It is envisaged that around 20-30 in-depth interviews and 6-8 focus groups will be required but we are open to suggestions. 7.3 Tenderers are invited to propose a detailed qualitative methodology, including details of sampling, recruitment and analysis. Please also state the expected duration of these interviews and focus groups and mode, e.g. face-to-face, telephone etc. The successful contractor will need to demonstrate their experience (organisational and key personnel proposed for the project) of designing and conducting qualitative research. 7.4 Bidders are invited to suggest different options for the qualitative element of the research, and to suggest recommended and minimal alternatives. Tenderers are asked to provide separate costs for the different options described in paragraph 7.3. They should also include costs for a sample of anonymised transcripts of the qualitative interviews and focus groups. 7.5 In approaching potential respondents, letters will need to be sent to the respondents in advance, both to give potential respondents the choice of opting out of the research, and to provide an interview brief. 8. Outputs 8.1 HMRC envisages the successful contractor to produce the following outputs (in electronic formats), although please note that this is still a provisional list of outputs: Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 6 Detailed project plan, outlining key dates and milestones, and clearly indicating any actions for HMRC; Briefing note on the pilot work. This should include a short discussion of the results of the pilot and the implication for the main stage fieldwork, including lessons learned; Regular progress updates, including survey response rates; Full dataset of the main survey in a format agreed with HMRC4 A copy of the questionnaire, other material and documentation. These will need to be sufficient to allow others to analyse the data in case the dataset is placed in HMRC’s Datalab; Details of the descriptive statistics and segmentation analyses, including the syntax or code used to produce these; A sample of transcripts of the qualitative interviews and focus groups; A slide pack for an interim presentation of top-line findings; Full report of the findings, presenting the results of the descriptive and segmentation analyses as well as the results of the qualitative research. Three presentations of the final results to HMRC with good quality presentation slides. 8.4 The contractor should assume that reports, questionnaires and fieldwork materials may need to be amended in the light of comments made by HMRC and that at least one draft, possibly more, will be required before agreeing a final draft. Allowance should be made for this in the proposed timetable and cost for the research. 9. Project team 9.1 Bidders should give details of their proposed project team, outlining their expertise and relevant experience. All personnel to be involved must be named in the tender and their roles and number of allocated days must be specified. The project team must include staff with relevant advanced experience and knowledge in survey design and methods. Proven ability to conduct research with businesses is essential, while experience of conducting research with the professional agent community would be desirable. Proposals should summarise the skills and expertise that particular members of staff bring to the team and clearly identify the project manager, with CVs included as an annex. 9.2 Tenderers are also expected to clearly indicate whether any elements of the project will be undertaken by different teams or not, and provide information about the structure of the project team and how work will be organised. HMRC expects bidders to nominate one named lead in their organisation who will oversee the whole project to ensure efficient communication between HMRC and the successful contractor. 9.3 HMRC acknowledges that considerable resources are required for the successful delivery of this project to time. It is possible that agencies invited to tender have the skills and ability within their organisation to undertake all or part of this survey but do not have sufficient resources required to 4 This anonymised dataset may be made available to a wider academic community through a HMRC secure environment. Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 7 successfully deliver the whole project requirement. We therefore encourage agencies to collaborate with other suppliers to ensure that they are fully capable of undertaking this work. 9.4 The proposal should specify details of which parts (if any) of the project will be sub-contracted, the name of the sub-contractor who will work on the project, their experience of related research, and their responsibilities within the project. Tenderers should specify the extent to which they have worked with any proposed subcontractor in the past. If it is proposed to sub-contract any of the work, the same details as those provided by the tenderer should be given about the qualifications, experience and responsibilities of staff involved along with a description of their respective roles and the management arrangements put in place. Ultimately, however, the successful contractor will be held to account for the performance of any sub-contractor and needs to demonstrate their confidence to successfully manage sub-contractors. 10. Proposed Project Timetable 10.1 The timetable for the procurement and research tasks is outlined in the table below. The dates outlined for various stages are provisional. We anticipate that the contract will start in January 2014. The time allowed for fieldwork is particularly tight (7-8 weeks). Tenderers are asked to demonstrate that their field force is capable of completing the survey in this length of time, or provide alternative suggestions, which still allow key deadlines to be met. Ideally, around two thirds of the fieldwork would be completed by the end of March 2014. Table 1: Proposed procurement and research timetable Procurement Research Reporting Activity Issue ITT Deadline for ITT Interviews (if needed and Contract awarded) Set-up meeting Quantitative research preparation Quantitative fieldwork Segmentation analysis Date 6 January 2014 24 January 2014 w/c 3 February 2014 w/c 10 February 2014 February March to mid April Late April to mid May 2014 Qualitative research preparation Qualitative fieldwork Interim presentation of headline results to HMRC Report of results (both quantitative and qualitative) delivered to HMRC Two or more presentations of the results to HMRC May 2014 Late May to mid June 2014 Mid June 2013 End of July 2014 End of July to early August 2014 11. Quality and Risk Management 11.1 The contractor must provide a quality control plan with their proposal that demonstrates their internal procedures to assure quality control. In particular this should include measures to quality assure fieldwork design; fieldwork procedures and quality assuring final outputs including datasets. HMRC would expect this to cover questionnaire checking; edit checks; data checks; strategies for achieving high response rates; management of fieldwork calls; monitoring of interviewer performance; strategies for minimising missing data and processes for delivering datasets. Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 8 11.2 Proposals should also include an assessment of the key risks to this project. This should identify the most significant risks to successful completion of the programme of work, assess the degree of risk (likelihood and impact), set out strategies for minimising these risks and managing the consequences if problems occur. For example, the quantitative segmentation not being validated during the qualitative fieldwork stage. See the separate excel sheet in Annex C as an example of the template HMRC require research contractors to complete. 12. Resourcing and Pricing 12.1 Tenderers are invited to propose how they would meet these requirements in the form of a programme of work. Tenderers must include a project plan and time schedule for the work that identifies the main tasks and key milestones that will be used to monitor progress, indicating clearly where HMRC is expected to contribute. The plan should also be accompanied by a resource profile, giving a breakdown of the resources in person days to each task. 12.2 The proposal must include a firm price offer (excluding VAT) and a breakdown of costs by: Table 2: Project costings Activity Personnel (level of staff) Number of days per team member Day rate per team member Overheads Survey preparation including telephone look-ups, the removal of duplicate businesses from the supplied sample and sending opt-out letters to potential respondents. Survey piloting and fieldwork including briefings, debriefings, data capture, editing and processing for the recommended and minimal designs (see Section 5.4). Data analysis (the construction of weights, descriptive statistics and segmentation analysis). Qualitative in-depth interviews and focus groups for the recommended and minimal designs (see Section 7.4), transcription costs and qualitative data analysis. The written report of the findings. Four presentations of the findings to HMRC (an interim findings presentation and three final presentations). Please also provide the cost of an additional presentation. Other costs; including administration, travel and subsistence. VAT (if applicable). Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 9 Total (£) Note: Tenders that do not supply a schedule of costs in the format outlined above will not be accepted. 12.3 Bidders are asked to clearly state whether the decision not to continue with this project at any stage would have additional costs associated for them, and to provide a justification for these costs. Any additional costs identified will be subject to negotiation and agreement with HMRC prior to any contract being awarded. 12.4 Please indicate whether VAT would be payable. This is not a factor in determining which tender is successful, but the information is useful to assist our financial planning. 12.5 In costing your tender you should allow for attendance at around three meetings to be held in central London. These might include the following: A set-up meeting A progress meeting A post-project review meeting 12.6 HMRC may require additional meetings and presentations to those as itemised in sections 12.2 and 12.5 above. Tenderers should supply costs per meeting and presentation. 13. Tender Evaluation Criteria 13.1 Tenders will be evaluated on best value for money. This will be judged on the basis of assessment of proposals (supplemented where relevant by discussion at interview) against the following quality criteria set against overall cost (excluding VAT): 13.2 how well the aims, objectives, policy drivers for the project and detailed information requirements are understood and addressed; fieldwork standards, data capture, processing and weighting strategies, how professional and ethics standards will be met; how well the tenderer demonstrates an understanding of segmentation analysis; the extent to which the tenderer demonstrates expertise in qualitative research; proposed team composition and its expertise in conducting research with agents/businesses, including the team’s project management skills and the ability to deliver the research to tight timescales. Tenders will be evaluated against the above criteria using the five point scale below. All criteria will be equally weighted. Score 0 1 2 3 4 Description Totally fails to meet the requirement Meets some of the requirement, with limited supporting information Meets some of the requirement, with reasonable explanation Fully meets the requirement, with detailed explanation/evidence in support Exceeds the requirement, with detailed explanation/ evidence in support Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 10 13.4 Whilst contract price will be an important consideration, it is only one of a range of important factors affecting any decision to award a contract. Therefore HMRC reserve the right not to accept the lowest priced (or any) tender. 13.5 HMRC will select the successful tendering organisation(s) based on the criteria above. Tendering organisations may be invited to interview by the HMRC before the selection is made, with interviews provisionally scheduled for early February 2014. Following selection, any necessary post-tender negotiations will be held with the preferred supplier in order to finalise the work programme prior to awarding the contract. Any contract offered in connection with this research will be subject to the Terms and Conditions of the Framework Agreement. 14. Commissioning Conditions 14.1 The DWP/HMRC Research Framework 2013 Terms and Conditions will form the basis of the contractual agreement between the successful tendering organisation and HMRC. 14.2 The contractual agreement will be subject to the contractor complying with the Official Secrets Acts and related Legislation including Section 18 and 19 of the Commissioners or Revenue and Customs Act 2005. 14.3 HMRC retains the option of whether or not to commission the study, or any element of it. 14.4 Terminating the contract - HMRC reserves the right to terminate the contract prematurely (for any reason) should this be deemed necessary. In the event that it would become necessary to terminate or adjust the contract, HMRC will cover costs for services provided up to that point. Contractors should not book or schedule fieldwork until written confirmation has been provided by HMRC. Contractors should provide a cancellation policy, including details of charges (if any) should it be necessary to cancel fieldwork. 14.5 Additional contractual information is included in Annex B. 15. Data Security and Protection 15.1 The successful contractor will be required to submit a security plan before the start of the contract. This will detail your approach to safeguarding confidential information including your company policies for handling sensitive documents and computer files from unauthorised access. 15.2 If you intend to involve sub contractors at any stage of the project please include details of how you will ensure their compliance with all aspects of the Security Plan. 15.3 The requirement on Data Security is set out at Schedule 5, Appendix 6 of the Framework Call off Terms and Conditions. A Security Plan questionnaire is attached (please see Annex D). Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 11 16. Other Ethical Issues 16.1 To preserve confidentiality and anonymity, details of individual participants in the research must not be included in the analysis and reports 16.2 Published outputs of statistics will be consistent with statistical disclosure guidelines, as advised by HMRC. 17. Procurement Transparency 17.1 HMRC is obliged to publish tender documents for all contracts with a whole life value of over £10,000. It is a condition of bidding for this work that applicants agree to the subsequent publication of the contract once awarded. 17.2 If Bidders believe that any of the information requested is commercially sensitive they should provide such information in a separate letter. 18. Research Management 18.1 The HMRC project manager for the work will be Eleanor Rutherford. She will be responsible for the day-to-day management of the contract. Once the contract has been awarded, all contact with HMRC concerning the project should be made through her. The research organisation will be required to appoint a contract manager who will act as the principal point of contact for the Department. 18.2 The research organisation will be expected to work closely with the HMRC project manager and through her, with internal customers within HMRC throughout the duration of the contract. She must be kept informed of progress and be involved in key decisions. Proposed changes in project staffing (at all levels) or deviations from the agreed work programme must be discussed and agreed with the project manager in advance. She is responsible for all decisions that involve funding. 18.3 In costing your tender you should allow for attendance at a minimum of 3 meetings in the 2013/14 and 2014/15 period as discussed in Section 12. The majority of meetings are expected to take place at HMRC offices in London, although some may take place at the research organisation’s premises by arrangement. 19. Summary of Requirements 19.1 Tenders should include the following information: A summary of proposals including a firm price bid (exclusive of VAT) as detailed in Section 12; A detailed explanation of proposals to meet the aims and objectives outlined above. This should include details of methodology; A detailed timetable for the proposed research for each specific information requirement, taking into account that outlined in Section 10; Quality control procedures and risk register as outlined in Section 11 (as annexes); Curriculum Vitae of key personnel proposed, their status within the company, area of expertise and details of their individual chargeable day rates; Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 12 tm quadrangle © 7 page 2009 included in the )Not research makers Low No Yes for decision Perception Rule Breakers Need Willing Prioritisation Ability Able cash Ongoing Potential Payment Unaware difficulties of Acceptability Awareness Deferrers Hidden Boundary Risk payment evasion Breakers flow Help but and economy Rule Payment pushers segmentation Segmentat ion overview Chargeable rates for other personnel proposed. Where these can be identified as groups (e.g. administration, support etc.) then a group rate will suffice; Any further costs identified. Tenders should not exceed 30 pages (excluding Annexes). Information included after this limit will not be considered under the tender evaluation process. 20. Contact details and queries on the ITT 20.1 Please send any queries you have to [Redacted under Section 40 of the Freedom of Information Act]. Note that all queries will be shared between contractors. The deadline for submitting queries on the tender will be 4pm on 20th January 2014. 21. Information on How and When to Return Tenders 21.1 Tenderers should notify of their intention to submit a proposal by email to [Redacted under Section 40 of the Freedom of Information Act] by 4pm Friday 20th January 2014. 21.2 Bidders should submit a tender stating how all the requirements outlined in this document will be met. The proposal must contain sufficient information to enable HMRC to evaluate the proposals. 21.3 Please read the enclosed Instructions for Tenderers (Annex A) carefully. 21.4 Please email a PDF or read-only version of your tender to [Redacted under Section 40 of the Freedom of Information Act] and [Redacted under Section 40 of the Freedom of Information Act]. Tenders should be submitted by email by 5pm on 24th January 2014 (unless the date is subsequently amended in writing by the Department). In summary, tenders should note the following: Action Deadline Notify your intention to 4pm on 20th January 2014 submit a proposal Submit queries on ITT 4pm on 20th January 2014 Submit read only tender 5pm on 24th January 2014 via email Contact [Redacted under Section 40 of the Freedom of Information Act] [Redacted under Section 40 of the Freedom of Information Act] [Redacted under Section 40 of the Freedom of Information Act] HMRC, January 2014 Protective Marking: OFFICIAL UNMARKED. Do not copy, cite or circulate this document without prior permission from HMRC. 13
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