Draft Legislation: Enhancing HMRC’s powers: tackling tax adviser facilitated non-compliance

HMRC are consulting on draft legislation on Enhancing HMRC's powers: tackling tax adviser facilitated non-compliance avoidance (‘the Consultation’) which was issued on 21 July 2025.

The Consultation introduces legislative changes designed to strengthen HMRC’s ability to deter and respond to tax adviser behaviour that facilitates non-compliance.

The measure includes:

• changes allowing HMRC to request information from tax advisers where there is reasonable suspicion of deliberate conduct
• penalties for tax advisers who engage in deliberate conduct, calculated based on the tax loss
• a new power allowing HMRC to publish details of advisers where they have been sanctioned

The measure is part of a wider package to raise standards in the tax advice market and reduce the tax gap.

The Consultation closes on Monday 15 September.

If you have any comments on the draft legislation, please contact Steven who will be leading on the ATT response.