24 July 2025
HM Revenue and Customs (HMRC) has confirmed, through draft legislation, the measures being introduced for tax advisers.
Along with the requirement to register as a tax adviser, which may capture payroll professionals delivering a service, this may be something that you need to be aware of and keep on top of.
The changes will be as follows:
“Legislation will be introduced in Finance Bill 2025-26 to amend schedule 38 of the Finance Act 2012. The changes will:
- allow HMRC to obtain information from tax advisers using a file access notice where there is reasonable suspicion that they have facilitated non-compliance in their clients’ tax affairs
- remove the requirement for tribunal approval before issuing a file access notice, replacing it with a senior HMRC officer approval mechanism
- revise the penalties for failure to comply with a file access notice to include where inaccurate information is provided, and allowing HMRC to increase the penalty amounts where approved by the tribunal
- introduce a new penalty framework for where HMRC establishes that a tax adviser has deliberately facilitated non-compliance in their clients’ tax affairs
- introduce new powers to publish information about tax advisers where HMRC has used relevant sanctions.”
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