My thoughts on the current discussion
I think there are more levels to discuss
on the transport or security aspect. If I elaborate on your truck example
You can make a choice for a car/truck
to deliver packages
You can tell people to take a specific
route or road
You can tell people if you take that
road, please be careful and keep you speed limited to 60
You can act like the police and check
if everybody is driving according to the rules
My point here: I also think that transportation
is less relevant, but transportation is linked to security. And i do think
security is relevant.
The question is: do we need or want
security?
If yes: who wants it, who is responsible?
Everybody, so nobody?
If my bank opens an office in a very
bad neighbourhood (and the internet is not a safe place!) and asks me to
bring my money (tax data), can I hold the bank responsible for my safety?
Probably not, and that is why i do not carry much money with me and
go to another bank. With tax filing i do not have much choice. And may
be tax regulators will consider the safety of the people and feel at least
a bit responsible for helping people to bring their money.
What is security? "People should
be able to send their packages (tax data) and get confirmation on:
The package was received by the right
party, in time and in the same order as it was send. "
F.i. the CobIT framework can be considered
as an open standard to achieve these purposes. I am not trying to
complicate things, more connecting. The group should decide if the connection
is relevant. If the goal of this group is to connect different standards
(and make choices) to enhance the tax filing process (and make it more
easy for the 'clients'), then security can be part of the discussions,
i think.
A starting point for further development
could be the model on page 16 of the position paper. Would it add value
to reconsider this model and add more details (I have seen some pretty
impressive models in the group, and these are not part of the document,
unfortunately), f.i. the layers Andy mentioned in his email?
The way i see it: if the group evaluates
different standards, this implies the existence of norms for the actual
assessment. The filing process should the basis of that. There is
some material in the position paper, but not very explicit.
The model could force you to take an
explicit standpoint (just examples of what i am trying to make clear)
"Our tax organisation never wants
to be dependent on one standard, unless it is open."
"We never want to use just one
standard, open or proprietory."
"We find we are responsible for
the process starting at A and ending at B." The same with levels in
the process.
"Whe like the standards we use
to have as minimal overlap as possible"
"CHoices between as little standards
as possible against the best of breed"
"Try to use as much as possible
exisiting business reporting infrastructure in companies"
"Try to convince as much software
vendors to participate"
...
---------------------------------------------------------
Met vriendelijke groet / best regards,
Marc van Hilvoorde
PricewaterhouseCoopers Accountants N.V.
Global Risk Management Solutions
tel.: +31 (0)30 219 1706
www.pwc.com/nl/xbrl
"Sylvia Webb" <>
07-07-2004 22:11
Please respond to swebb
To:
"'Andy Greener'" <>,
<>
cc:
Subject:
RE: [tax] Issues for v2.0 of position
paper
-----Original Message-----
From: Andy Greener [mailto:]
Sent: Monday, July 05, 2004 9:33 AM
To:
Subject: [tax] Issues for v2.0 of position paper
During the recent conf call Harm Jan asked for suggestions/issues/ ideas
for
the next version of the Position Paper to be discussed on this list. This
is
a shameless attempt to kick-start the discussion!
Of the issues outlined for discussion in Washington, but not really
addressed, I think we can all but eliminate a couple right away (but please
feel free to disagree :-):
Transport: about as relevant to Tax as the make of truck FedEx use to
deliver packages. We should be entirely independent of any transport
mechanisms, whether locally defined or based on standards. In an ideal,
strictly layered, world transport would be hidden well below our boundary
of
interest. However, the world is not ideal and practical transport
restrictions do sometimes intrude. For instance, in the real world there
are
often practical upper limits on the size of messages (no use trying to
FedEx
a package bigger than their biggest truck). Whilst we should not be trying
to specify transport mechanisms we can set acceptable parameters (such
as
minimum supported message size) and design our document framework in such
a
way that we can accommodate them.
==>Webb: I agree
Closely allied to transport, and treated in the same way, are generic
message formats such as MIME, DIME and SOAP. We should not care that tax
documents (or other business documents with tax components) are cast into
particular transport-oriented message formats for transmission, but again,
there are untidy bits poking through the nice clean layers that need to
be
accommodated.
Further work is needed to identify those aspects of tax domain documents
that might need special provisions in any document standards we develop
or
adopt, or that might impose certain requirements on underlying transport
formats and protocols.
===>Webb: There is another generic message that is in the approval process
at UN/CEFACT called the Standard Business Document Header. It was sponsored
by UCC but has gained the interest of other industry groups. It is at the
application level not the transport level and may need to be reviewed as
well.
(We have a particular case in point in the UK: a message size limit of
25Mb
is imposed by the Govt Gateway for good practical reasons, and whilst this
would be unlikely to influence the design of an invoice Schema it does
influence the design of Schemas for large tax documents that may approach
or
exceed this size - eg. our largest employer produces 200Mb+ of XML relating
to annual employee payroll tax deductions and National Insurance
contributions. Use of the UK Govt Gateway is imposed upon the UK tax
administration by Govt-wide policy - it is not a choice that the tax
administration is at liberty to make, and the same will likely be true
for
tax administrations in most other jurisdictions operating within the
confines of some sort of e-Government structure or framework)
Security: for the same reason that XBRL Int'l have rejected any specific
support for security from their standard, so must we. Though it is applied
to payloads, security in all its forms is not an integral part of a payload.
The term "Security" also covers a multitude of sins - including
but not
limited to confidentiality, integrity, authentication, authorisation and
non-repudiation. There are well-known ways of achieving all these aspects,
and again, they are likely to be choices outside the control of individual
tax administrations - jurisdictional policies are much more likely to play
a
key part in the choice of applicable standards.
===>Webb: I agree.
Web Services: we probably need to discuss the scope of this and its
applicability before coming to any firm conclusions. It is easy to see
how
recommendations in this area would be of practical use to tax
administrations - I'm just not sure I know exactly what the scope is and
exactly which way the wind is blowing in the Web Services standards world
just now.
Document structuring: we've really only scratched the surface of this in
the
present paper by making no more than passing references to UBL, OAGis and
CICA. We need to be a lot clearer on where these standards are competing
or
complementary (for instance, ebXML Core Components seem to be a common
thread leading to at least some convergence) and how we might utilise them
in any standards framework we recommend.
===>Webb: I agree. Further, how ebXML Core Components are being implemented
in UBL, OAGIS, and CICA are different. As an example, UBL is trying
to
become harmonized with UN/CEFACT ATG2 for both Core Component Types and
NDR.
OAGIS and CICA are only adopting CCT's. What does this really mean
from a
message design and standards adoption prospective?
IMHO, we also need to explore what the pros and cons are of creating another
standard versus adopting an existing one.
Both UBL and OAGis address indirect tax already of course within their
respective document framework definitions, and our indirect tax review
is
meant to get to the bottom of the differences and produce a reference model
by which these standards can be judged, but I see the direct tax domain
as
an extension of the business document structuring techniques provided by
these standards. These are two sides of the same coin: a supply-chain
business document is simply a structured business-oriented document with
some tax-specific as well as generic components, and a tax return document
is simply a structured tax-oriented document with some generic as well
as
tax-specific components. Fundamentally they are structured document
templates designed for a specific purpose and containing a number of
specific and generic, re-usable, components.
I'll leave it at that for now. Please feel free to comment on, challenge
or
even agree with(!) any of my statements, assertions or assumptions.
Andy
--
Andy Greener
Mob: +44 7836 331933
GID Ltd, Reading, UK
Tel: +44 118 956 1248
Fax: +44 118 958 9005
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