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ATT raises tax consultation concerns with Minister and HMRC Chief Executive

29 September, 2026

The ATT has written to the Financial Secretary to the Treasury, James Murray MP, and to HMRC's Chief Executive, JP Marks, to express concern over HMRC's recent approach to public consultation. You can read a copy of our letter here. 

The letter follows a total of eighteen public consultations being issued across Tax Update Day and Legislation Day this summer. Whilst we welcome this type of consultation, the ATT is concerned that external stakeholders are being brought into the picture at too late a stage, preventing us from helping to define a policy problem and contribute to the best possible solutions. 

Recent engagement has tended to involve HMRC consulting on part-formed solutions to a policy issue, seeking views on how best to implement their preferred approach to tackling it, without first gathering insight on a wider range of options. 

A recent joint letter to Ministers indicates a desire in Government to reduce formal consultations where possible, in favour of a more flexible approach "involving a wider range of people in shaping our thinking earlier and more directly". 

In our letter, the ATT cautiously welcomes the idea of "more participatory policymaking" but expresses concern over the importance of HMRC gathering an appropriate spectrum of external views, noting that this may be challenging without the formal process of publishing consultations.