Picture showing Houses of Parliament, specifically the Elizabeth Tower

ATT gives evidence to House of Lords Finance Bill Sub-committee

13 November, 2026

The ATT has submitted written evidence to the House of Lords Finance Bill Sub-committee, which is reviewing the draft Finance Bill 2026-27.

Our written evidence covered three main areas:

  • Modernising the correction of errors
  • Criminal offence of reckless untrue statements and declarations
  • Mandatory payrolling of benefits in kind from April 2027

In respect of modernising the correction of errors, we felt that there are significant uncertainties regarding how this measure will operate in practice, which are not helped by the use of subjective and widely defined terms in the legislation. We also believe the proposed sanctions are not coherent, identifying that it is proposed that a failure to act when prompted by a correction notice will be treated less severely than failure to come forward when the taxpayer is aware of an error.

On the criminal offence of reckless untrue statements and declarations, we support the government's objective of tackling tax fraud and promoting a tax system that is clear, consistent and proportionate. However, we do not support the introduction of a new criminal offence as it is our view that HMRC have not adequately established that the existing framework of civil penalties and criminal offences is insufficient to address the concerned behaviours

Our Technical Officer Chris Campbell gave oral evidence to the committee on the mandatory payrolling of benefits in kind on 29 October 2026.  A recording and transcript of the session is available on the UK Parliament website. 

In our oral and written evidence, we noted concerns regarding delays in HMRC publishing practical guidance and limited publicity to date, which may result in many employers not being adequately prepared for changes that are due to take effect in a matter of months. Whilst supportive of the phased implementation of mandatory payrolling, we felt that HMRC did not move forward with sufficient pace in terms of making the required guidance available as early as it was needed by employers and software providers. We also felt that HMRC had underestimated the likely cost to employers in terms of administration, especially in year one and the early years of moving to mandatory payrolling.