Ahead of HMRC’s Annual Stakeholder Conference, the Institute sent a letter of introduction to HMRC’s new CEO.
Any letters and submissions referenced are available to read at: https://www. charteredaccountants.ie/knowledge-centre/Tax/Representations/2025.
IHT reliefs
In April this year, the Committee wrote to the Exchequer Secretary to the Treasury to raise its concerns about the disproportionate impact of the proposals to curtail the benefit of APR and BPR, particularly in NI, on genuine farming activity and family owned businesses.
Just before Legislation day on 21 July, HM Treasury responded to this letter which essentially suggested that the Government was not planning any significant mitigations to these proposals. This was confirmed on L-day when the Government published draft Finance Bill clauses. Chartered Accountants Ireland issued a Press Release reacting to this which calls for a special derogation from these changes for NI.
In September, the Institute met with senior representatives from Government in NI to discuss this. In early October, a submission was made to the House of Lords Finance Bill Sub-Committee inquiry into ‘Draft Finance Bill 2025-26’. Subsequently, the Institute gave oral evidence to the inquiry hearing at the Palace of Westminster. The Institute’s full response to the House of Lords will be published in due course, once the Committee has published its final report.
L-day consultations
In September the Committee responded to three technical consultations on draft legislation launched on L-day, two of which fall under HMRC’s ‘Raising standards in the tax advice market’ project. A response was also submitted to the consultation ‘Making Tax Digital for Income Tax and penalty reform’.
Enhancing HMRC’s powers and sanctions against tax adviser facilitated non-compliance
This proposes to enhance HMRC’s powers against agents who facilitate non-compliance and includes the following measures scheduled to commence from 1 April 2026:
• Issuing file access notices to advisers suspected of facilitating non-compliance via deliberate behaviour,
• Significantly increased penalties for such behaviour, and
• Publication of details of advisers subject to any HMRC agent sanction.
The key recommendations in the submission are that implementation should be paused to commence no earlier than 1 April 2027, given concerns about the lack of effective safeguards in the draft legislation and the highly disproportionate penalties.
Modernising and Mandating Tax Adviser Registration
This proposes that from 1 April 2026 all tax advisers who interact with HMRC on behalf of their clients must register with HMRC and will not be registered unless they meet ‘minimum standards’. Anyone who is not registered will be unable to represent their clients.
Registration applications will require each ‘senior manager’ (those at the highest level) in the business to meet certain conditions including, inter alia, that they have no outstanding tax returns or payments and that they meet any standards laid down by HMRC. There are also powers for HMRC to monitor eligibility and compliance with the rules on an ongoing basis and hefty sanctions for agents who fail to comply.
Given concerns that the proposals are a form of quasi-regulation of members of Professional Bodies who are already subject to regulation, the Committee recommends that registration be delayed to no earlier than 1 April 2027. In addition, the definition of ‘senior manager’ should only apply to those who provide tax services. Further detailed consultation is required on the proposed sanctions, given the link to the potential for the agent’s details to also be published.
Letter to HMRC CEO
Ahead of HMRC’s Stakeholder Conference, the Institute wrote a letter of introduction to its new CEO, JP Marks, setting out four key issues on our agenda:
• The Institute’s campaign for a lower rate of corporation tax in Northern Ireland,
• The tax burden and complexity arising from cross-border and remote/hybrid working,
• Tax simplification and the lack of progress in this area, and
• Making Tax Digital for Income Tax and the implementation of mandatory tax adviser registration from 1 April 2026.
The Institute was represented at the conference by our UK Tax Manager, Leontia Doran. Under the conference theme ‘Navigating the future together: the Transformation Roadmap in Action’, attendees heard more from JP about the ambitious plans in its Transformation Roadmap which was launched on L-day in July.
In his speech, JP spoke frankly about the challenges which lie ahead but importantly also recognised the need for greater openness and transparency. He set out his vision for even greater collaboration between agents and HMRC in which he sees both groups working together as stewards and custodians of the UK tax ecosystem. Attendees also heard from the new Exchequer Secretary to the Treasury, Dan Tomlinson MP.
There was also an opportunity to take part in a series of workshops, all of which were themed around the roadmap, and which provided the Institute with a key opportunity to directly engage with several senior leaders in HMRC.