As previously reported in Tax Stamp & Traceability News™, the international standard for excise tax stamps, ISO 22382:2018, is now due its five- year review, in accordance with ISO procedures (the International Organization for Standards).
I have been appointed project leader for this review, so I’ve been taking informal soundings from stakeholders (tax stamp issuers, suppliers, the International Tax Stamp Association – which is supporting this work) to learn how the standard, published in 2018, could be improved.
As part of these discussions, I ran a workshop at the recent Tax Stamp & Traceability Forum™, attended by around 80 people, including some 20 revenue agency representatives.
The workshop included an engaging, lively, and informative discussion, showing that the standard is valued within the tax stamp world and that stakeholders want to contribute to making it better.
The discussions – particularly the comments from revenue agency representatives at this workshop – have been very helpful in identifying topics to consider as part of this review.
The full title of the standard is ‘Guidelines for the content, security, issuance and examination of excise tax stamps’, and it is intended to provide guidance to stamp issuers – mainly treasuries and revenue agencies. So, it has been especially valuable to hear the view of some of these agencies that the standard needs to be more accessible for their staff.
The standard gives much information on the technical construction of substrate- based tax stamps, including detailed guidance on security and authentication features, serialisation, and unique identifiers. However, it has become apparent that this level of information discourages some revenue agency staff from paying attention to the standard. That said, this is important guidance information to convey, so it should not be left out of the standard. So, how to reconcile these seemingly conflicting requirements?
The approach adopted by the ISO group responsible for this standard – Working Group 4 of Technical Committee 292, at its meeting in mid-October – is to focus the body of the standard on the processes and procedures of revenue agencies in defining their tax stamp needs and how to meet them through their procurement procedures. The standard will still, of course, include guidance on stamp construction and security, but the detailed information on these items will be in annexes, ie. additional sections on specialist topics.
In the current version of the standard the annexes are informative, ie. they add information to what is in the body of the standard. However, the revised standard will have normative annexes, ie. they are a more formal part of the standard which need to be followed by agencies using the standard in order to guide them. (‘Informative’ and ‘normative’ have specific meanings in ISO’s terminology).
Another change which WG 4 adopted is to remove ‘excise’ from the title of the standard. A simple but significant change in recognition of the fact that stamps are now used as a means of collecting tax on goods which might not usually be seen as subject to excise tax.
Having accepted these important changes to ISO 22382, WG 4 will now proceed to further review and rewrite the standard, a process that is likely to take 15-18 months.
WG 4 has accordingly established a small drafting group to work with me on this review, and several representatives of International Tax Stamp Association members are on that drafting group.
If you have information or ideas that will help this review to produce a much- improved standard for tax stamps, please contact me at ian@lancaster-consult.com..
