Autumn 2026 Pre-Budget submission
In any given year, there is a myriad of tax policy initiatives which deserve attention. At the same time, a Government and its departments will have necessary constraints driven by resources and capacity that often require urgent action. Our work here at the Institute gives us a ‘front row seat’ in the policymaking process which, when combined with evidence from our members, informs on what our focus should be in any particular year.
In this year’s Pre-Budget 2026 Submission, we are addressing the absence of proper consideration of regional differences in UK tax policy making and making specific proposals which we believe are crucial to unlocking the true economic potential of Northern Ireland. In order for the UK as a whole to remain an economic world leader into the 21st century, Westminster must take bold action to unlock the potential of the wider UK, not least of all Northern Ireland (NI).
The Institute’s submission, therefore, focuses on three areas of strategic importance to NI and in turn the UK as a whole:
1. Reforming the tax rules on cross-border and remote/hybrid working on the island of Ireland, including modernising the UK-Ireland Double Taxation Convention and/or introducing a bilateral agreement for frontier workers,
2. Refreshing the UK tax policy making framework to deliver greater stability and certainty for taxpayers and businesses, with measures and processes that deliver tax and administrative simplification and choices fully evaluated against specific regional needs and local economic variations, and
3. Ahead of the 30th anniversary of the Good Friday Agreement and the fifth anniversary of the Windsor Framework in 2028, committing to a pathway to devolve corporation tax powers to NI which would empower the region to compete more effectively for inward investment and help fulfil the region’s economic potential.
NI occupies a distinctive position within the UK economy. Businesses continue to navigate trading arrangements that differ from those in Great Britain whilst at the same time are competing internationally for investment. Dual market access has so far yet to fully realise the economic growth envisaged for the region that was hoped for by policymakers during the course of the post-Brexit negotiations and on the introduction of the Windsor Framework.
Against this backdrop, the Institute is recommending that the UK Government takes a fresh look at how UK tax policy can support the labour market, competitiveness, investment, and productivity in Northern Ireland. The importance of reforming the UK’s tax policy making framework to recognise the regional diversity across the UK is at the core of our recommendations to government this year. Recognition of regional diversity in UK tax policymaking is also crucial for not only Northern Ireland, but parts of England, Scotland, and Wales where local needs differ from those in larger urban centres, such as London.
The Institute is calling for measures that will encourage NI businesses to invest, innovate, and improve productivity. In a region where attracting inward investment is a priority, ensuring the UK tax system remains competitive in an increasingly challenging global market is critical to our long-term success and prosperity.
Submission to consultation: ‘Reporting company payments to participators – modernising the reporting framework’
In this submission made in June, which examines mandatory reporting of close company participator transactions, the Institute’s key recommendations are as follows:
• Many close company transactions are already reported to HMRC. The Institute therefore recommends that businesses should not be required to report information that HMRC already holds or is receiving from another source,
• Several categories of participator should be excluded from the proposed reporting requirement including passive shareholders, indirectly held interests, corporate participators (including any privately owned groups which may be owned by private equity), and trustee/ nominee shareholders,
• HMRC should conduct a full review of how it could better utilise the information sources already reported to create a more joined up picture of transactions with close companies. This can then be used by HMRC to take a more targeted approach to its compliance work on these companies,
• If HMRC is concerned that record keeping in this population is poor, then it should more frequently utilise its record keeping powers, including the ability to impose penalties,
• A one size fits all approach to reporting of transactions by close companies would not be proportionate or appropriate. A more targeted compliance and education approach is warranted utilising information HMRC already has at its disposal, and
• As HMRC intends to work with stakeholders to develop an appropriate framework for the future administration of CT, the Institute is keen that this begins with how the proposals in this consultation can be reframed to be more proportionate and targeted and is thus willing to work with HMRC towards that objective.
Submission to consultation: ‘Timely Payments in Income Tax Self Assessment (ITSA)’
In this consultation response submitted in August 2026, the Institute warns that the proposed changes to the timing of income tax self-assessment (ITSA) payments will create unnecessary complexity, cash flow pressures, and administrative burdens for taxpayers, agents, and employers. Urging the Government to reconsider the current proposal for ITSA taxpayers to make more timely payments, particularly the proposal to collect via the PAYE system, the Institute views the proposals as disproportionate in light of the wider economic, human, and administrative challenges which would arise.
The consultation follows the Government’s announcement in the 2025 Autumn Budget that from April 2029 self-assessment taxpayers with PAYE income will be required to pay their forecast ITSA liabilities in-year through PAYE. HMRC is also exploring more frequent payment arrangements for other self-assessment taxpayers.
The Institute’s response highlights a number of concerns with the proposals and stresses that any new payment regime must be proportionate, easy to understand, and supported by robust HMRC systems.
Although the Institute recognises the Government’s objective of reducing tax debt, the Institute cautions that significant practical challenges remain. Among the key issues raised are:
• the risk that forecast-based payments will not accurately reflect taxpayers’ actual liabilities, particularly where income fluctuates from year to year,
• the potential cash flow and economic impact on taxpayers who would be required to pay tax earlier than under the current system,
• the additional administrative burden that would arise for agents, employers and pension providers,
• the need for appropriate safeguards where taxpayers experience changes in circumstances, including significant improvements required in HMRC’s processes for issuing refunds, and
• the importance of providing sufficient lead-in time, guidance, and support before implementation.
The Institute also emphasised the importance of considering the interaction of any timely payment reforms with other major changes already affecting taxpayers, including Making Tax Digital for Income Tax. Any transition to a new payment model should minimise disruption and avoid creating unnecessary complexity for already compliant taxpayers.
The Government has indicated that it will consider stakeholder feedback and publish its consultation response in Autumn 2026. Any relevant legislation will be introduced in a Finance Bill ahead of implementation from April 2029.
Prior to responding to both of these consultations, the Institute had already discussed its concerns on these proposals with HMRC in a meeting after these consultations were announced at the Autumn Budget in 2025.