Finance Bill 2025-26 Committee: MPs pass measures on promoters and tax adviser registration

Measures passed by MPs included on vaping duty, carbon border adjustment, promoter action notices, registration of tax advisers, new conduct rules and advance tax clearances for major projects. 

Shadow ministers raised CIOT and ATT concerns on a number of the measures in the Bill. The opposition parties tabled a range of amendments and new clauses; however, they were all rejected by the government. 

You can view the amendments paper here. The Bill can be read here. Explanatory notes can also be read here. 

Sitting 5 – Tuesday 3 February 9:25am – 11:25am 

PART 4 - VAPING PRODUCTS DUTY  

Charging and administration (clauses 112- 116) 

Clause 112: Excise duty: Charge 
Clause 113: Vaping products 
Clause 114: Production of vaping products 
Clause 115: Excise duty point and payment 
Clause 116: Administration 

The Economic Secretary to the Treasury, Lucy Rigby, began the debate, suggesting that clauses 112 to 116 will establish a “coherent and enforceable” framework for the new vaping products duty and ensure that vaping products are “taxed appropriately”.  

The Shadow Exchequer Secretary (Shadow XST), James Wild, raised concerns about the broad definition of vaping products, particularly the inclusion of zero-nicotine liquids. He said that “the apparently popular zero-nicotine shortfills used by smokers who are trying to quit or taper down will be taxed, too”.  He cited reporting from Vape 360 indicating a 203% price increase for shortfills. Wild further pressed for clarity on enforcement, asking if HMRC had sufficient resources to manage this new duty regime. 

In response, the minister defended the zero-nicotine approach and said that “the definition is deliberately broad to reflect how the market operates and to support what we hope will be effective enforcement”. She added the government approach will give HMRC “clear rules to work with”, enabling quick decisions at the border.  

Clauses 112 – 116 - passed 

Stamping of vaping products (clauses 117 – 120) 

Clause 117 - Stamping of vaping products 
Clause 118 - Issue and management of stamps 
Clause 119 - Approved stamp holders 
Clause 120 - United Kingdom representatives 

The Economic Secretary highlighted that these clauses would ensure that vaping products duty is robustly enforced through a secure duty stamps regime and that all manufacturers, whether they are based in the UK or overseas, are subject to clear accountability. 

The Shadow XST and the Liberal Democrat spokesperson, Joshua Reynolds, broadly supported these clauses. Wild suggested that the government could move toward a “fully digital stamps” which would be “harder to counterfeit… and better aligned with the government’s stated commitment to a digital-by-default tax system”. 

The minister replied that the approach would be harder for consumers and trading standards officers to use on shop floors, and could impose “greater burdens” on small retailers than a visible stamp. 

Clauses 117 – 120 - passed. 

Forfeiture, civil penalties and enforcement (clauses 121 – 125) 

Clause 121 – Forfeiture 
Clause 122 - Dealing in unstamped vaping products 
Clause 123 - Loss and misuse of duty stamps 
Clause 124 - Failure to comply with this Part, etc 
Clause 125 - Forfeiture: civil penalties 

The shadow XST highlighting HMRC's “significant powers over forfeiture” and civil penalties, emphasising that the challenge is to “ensure that is done in a proportionate way”. In response the Economic Secretary said: “Given the judicial or criminal processes associated with the use of these powers, it is entirely fair to say that all the usual processes around charging, in a criminal sense or otherwise, will apply”. 

Clauses 121- 125 – passed 

Offences (clauses 126-130) 

Clause 126: Dealing in duty stamps 
Clause 127: Dealing in unstamped vaping products 
Clause 128: Sales ban following conviction for unlawful use of premises 
Clause 129: Offences: penalties 
Clause 130: Forfeiture: offences 

The Economic Secretary summarised that these clauses represent a “comprehensive suite of enforcement” tools that support the government to address the illegal trade and support the legitimate industry. She continued that the strong penalties, including custodial sentences, are “justified” due to the size of the illicit vaping market in the UK. 

Clauses 126 – 130 - passed 

Implementation provisions (clauses 131 – 138 plus government amendments 13 and 14) 

Clause 131: Publication of information 
Clause 132: Information sharing 
Clause 133: Investigation and enforcement 
Clause 134: Regulations: further provision  
Clause 135: Regulations: procedure 
Clause 136 and Schedule 14: Amendments of other instruments 
Clause 137: Interpretation 
Clause 138: Commencement and transitional provision 

The Economic Secretary explained that amendment 13 clarifies drafting to ensure elements of the regulations can come into force “at the proper time”, while amendment 14 puts the criminal offences under these schemes so that they can apply to vaping products, regardless of the date that they were produced or imported. She said that these amendments ensure that the duty can be “successfully administered”. The shadow XST did not oppose any of these clauses. 

Clauses 131 – 138 – passed as well as the government amendments. 

PART 5 - CARBON BORDER ADJUSTMENT MECHANISM  

Introduction and exemptions (clauses 139 - 147 plus government amendment 15) 

Clause 139: Introduction to Carbon Border Adjustment Mechanism (CBAM)  
Clause 140 & Schedule 15: Charge to CBAM  
Clause 141: Importation 
Clause 142: Goods processed under a special customs procedure  
Clause 143: Person liable: the importer  
Clause 144: Exemptions 
Clause 145: Embodied emissions 
Clause 146: Rate  
Clause 147: Carbon price relief 

The Exchequer Secretary (XST), Dan Tomlinson, told the committee that this measure is “central” to mitigating carbon leakage and supporting the UK’s path to net zero. 

The Shadow XST cited the Chartered Institute of Taxation (CIOT), which, he said, “has provided considerable help and input on all the provisions of the Bill”, and here had flagged that additional uncertainty may arise due to questions about the UK and EU emissions trading schemes being linked before the implementation date. He asked if the minister could provide an update on the formal negotiations with the EU.  

He also raised the CIOT’s concerns about businesses that operate through VAT groups, saying: “It is unclear how the measures affect those liable under the clause where one VAT group member uses another’s EORI [economic operators registration and identification] number.  If the current easement does not apply to CBAM goods, each member may need its own EORI number, which would add some complexity and administrative burden.” He asked the minister to clarify the position and consider additional legislation to allow for CBAM grouping. 

On clause 146, the Shadow XST suggested that a quarterly adjusted tax rate may make it “more challenging” for manufacturers and importers to price long-term contracts, plan investments or manage risks. 

In response to the question about groupings and EORI numbers, the XST said that the government has engaged with businesses in advance of making the proposal, and feedback indicated that group treatment would “confer relatively minimal benefits”, so the government chose not to implement it at this time. They would keep it under review though, he added. 

Clauses 139- 147 – passed as well as government amendment 15, which clarified that scheme years in which “there were no sectoral emissions should be ignored when determining the baseline free allocation percentage in relation to a CBAM sector”. 

Clauses 139 - 147 plus government amendment 15 passed. 

Administration and enforcement (clauses 148 – 149 and schedules 16 and 17) 

Clause 148 & Schedule 16: Administration and enforcement 
Clause 149 & Schedule 17: Criminal offences 

The Economic Secretary highlighted that both these clauses provide the “necessary administrative and enforcement backbone” for CBAM, ensuring the regime is “credible, enforceable and fair”. Meanwhile, it gives HMRC the tools it needs to administer CBAM effectively.  

The Shadow XST did not oppose these clauses, but stressed that businesses need “certainty” that this will be a “fair and workable system” and that does not add complexity that undermines competitiveness. This point was also raised by Joshua Reynolds, who argued that lots of businesses are not familiar with CBAM tax concepts. The Lib Dem spokesperson also voiced concern about the £50,000 threshold, adding: “I am interested to hear from the minister what verification and changes have been made, and what assessment has been made of the compliance costs for various businesses”. 

The Economic Secretary acknowledged the potential burden on businesses, but said that the UK CBAM will operate like a “conventional tax”. She continued that, to reduce administrative burdens, where possible the government will align with and build upon existing methodologies for calculating embodied emissions. 

In relation to the threshold concern, the minister argued that the threshold will retain over 99% of CBAM imports while removing 80% of otherwise registrable businesses, and that over 70% of those removed from CBAM altogether by the threshold will be micro, small and medium-sized businesses. 

Clauses 148 – 149 and Schedules 16 and 17 – passed  

Supplementary and commencement provisions for CBAM (clauses 150 – 155) 

Clause 150 & Schedule 18: Supplementary amendments 
Clause 151: Emissions: meaning etc 
Clause 152: Interpretation 
Clause 153: Power to make provision for linked emissions trading schemes 
Clause 154: Regulations and notices 
Clause 155: Commencement and transitory provision 

The Economic Secretary highlighted that these clauses provide the “essential supporting framework” that allows for the effective functioning of CBAM. 

The Shadow XST noted CIOT's concerns about the volume of secondary legislation: “The Chartered Institute of Taxation has expressed disappointment that so much has been left to secondary legislation and guidance to address operational matters. That leaves businesses and advisers with uncertainty, less than 12 months before the implementation date”. He urged the government to learn from the EU's experience and commit to regular parliamentary updates on how the system is working. 

The Economic Secretary emphasised the government's commitment to international engagement and noted engagement through the UK CBAM international group, which "serves as a forum through which the UK government can understand the views of international partners and share updates.” 

Clauses 150-155 and schedule 18 - passed  

PART 6 - AVOIDANCE 

Prohibition of promotion of certain tax avoidance arrangements (clauses 156 to 162) 

Clause 156: Prohibition of promotion of certain tax avoidance arrangements  
Clause 157: Meaning of promotion 
Clause 158: Procedure 
Clause 159: Civil penalties 
Clause 160: Criminal offence 
Clause 161: Criminal liability of responsible persons 
Clause 162: Interpretation and commencement 

The Economic Secretary explained that these clauses are about targeting those who continue to promote tax avoidance, adding: “They are not intended to be directed against legitimate tax advisers who are operating to a high professional standard but, while acting in good faith, make genuine mistakes”. She said that the XST has asked HMRC officials to work with stakeholders in developing published guidance to address the fine detail of exactly how the prohibition will work in practice. 

Briefly explaining each clause, the minister summarised that these measures ensure that taxpayers and the UK tax system are protected from the harm caused by these promoters. 

Sitting 6: Tuesday 3 February 2 pm – 5:15 pm 

The debate on the promotion of tax avoidance arrangements continued in the day’s second sitting. 

The Shadow Economic Secretary opened the debate by stating that the Conservatives support the government's efforts to tackle tax avoidance and tax evasion. Mark Garnier raised CIOT’s concerns about the wording of clauses 157 and 162, stating: “The intention to prevent ineffective tax avoidance arrangements at source is noble, but ‘likely to be’ marketed is too loose”. He emphasised the need for further clarity, warning that the provision, if left unchanged, “could accidentally catch normal tax advice". He urged the minister to commit to “tightening up the wording” of the clauses and providing specific details. 

The shadow minister also questioned how the government would prove that someone is promoting arrangements that have “no realistic prospect” of success: “I ask because, as the Chartered Institute of Taxation points out, the term was not in the draft Finance Bill”. He noted that the consultation on this measure had been described as “very short, limited and confidential” and asked whether the minister and HMRC would consider running a “more open” consultation. 

The Shadow XST, James Wild, intervened to suggest “there would be merit in holding public hearings ahead of a Finance Bill's consideration in Committee, rather than just receiving written briefings.” 

Garnier agreed, arguing: “The more we discuss it in public, the more the general public will realise that avoiding tax is a very bad thing. Anything that highlights that point is to be welcomed, so I strongly urge the Government to do the right thing so that we can make this prohibition work and protect advisers who may simply have made an error.” 

Turning to clause 159, which lays out civil penalties including a financial penalty of up to £1 million if the prohibition is breached, plus an individual fine of £5,000 for each person who has participated in the arrangements, the Shadow Economic Secretary expressed concern that “the 30-day window for making representations is not enough of a safeguard”. He noted that currently “that is the only recourse: a person cannot make a formal appeal to the tax tribunal.” 

Garnier also pointed out that subsequent clauses include a “reasonable excuse” defence, and suggested that “not having such a defence [here] leaves open the possibility that the bad behaviour of one rogue actor will lead to the prosecution of the wider organisation.”  

Joshua Reynolds, the Liberal Democrat spokesperson, supported the idea that “aggressive tax avoidance” measures need to be “prosecuted”, but raised a question about the breadth of criminal liability and the absence of safeguards. He explained: “Clause 161… creates some problems… If the neglect standard is brought, it could catch directors for oversight failures, rather than for active wrongdoing”. 

Reynolds further raised a point about limited guidance from HMRC on how it will apply these sanctions in practice. He expressed interest in seeing whether the government are willing to provide annual parliamentary reports on prosecutions. The definition of shadow members “also lacks clarity”, he added. 

The Economic Secretary to the Treasury, Lucy Rigby, repeated that these clauses are not intended to be directed against legitimate tax advisers who operate to a high professional standard, but who may make a genuine mistake. She further explained that the power in clause 156 will allow HMRC to make regulations “only where arrangements have been or are likely to be marketed”, where they are unlikely to work and where they are likely to cause harm to taxpayers. Adding: “The power is not at all intended so that HMRC can ban advisers from recommending tax positions they think are right, based on all the facts of the law, but with which HMRC disagrees.” 

Rigby argued that the government has consulted “extensively” on these measures with industry, and in light of stakeholder concerns around the threshold to issue regulations, HMRC introduced the taxpayer harms test to limit what arrangements are caught by the measure, ensuring that “legitimate advisers are not in scope of the measure”. 

In an intervention, the Shadow XST said that the CIOT had also raised “the difficulty of dealing with promoters who are based outside the UK”, highlighting that the remaining active promoters who sell mass-marketed tax avoidance schemes all have some offshore presence. He asked how the measures would address this. 

Clauses 156 – 162 – passed  

Promoter action notices (clauses 163 to 173) 

Clause 163: Certification of promoters 
Clause 164: Promoter action notices 
Clause 165: Preliminary notices  
Clause 166: Disclosure of information by HMRC   
Clause 167: Appeal against a decision to issue a promoter action notice  
Clause 168: Civil penalties  
Clause 169: Publication  
Clause 170: Reporting to regulators, etc  
Clause 171: Extension of time periods  
Clause 172: Reasonable excuse 
Clause 173: Interpretation  

The Exchequer Secretary (XST), Dan Tomlinson, introduced this group of clauses, explaining that they introduce a power for HMRC to issue ‘promoter action notices’, which require businesses to stop providing goods or services where those services are used in the promotion of avoidance. 

The Shadow Economic Secretary supported the work of HMRC to protect the public from promoters of avoidance schemes and the “overarching principles” that drive these clauses. However, he raised a point that the scope of the proposals is wide: “We have concerns that the proposals could inflict collateral damage on legitimate actors in the wider markets”. 

While supporting clause 163, Garnier stressed that the issue is the difficulty of completing the process to “officially certify what a promoter actually is”. He continued that these promoters can be difficult to catch because some of them are based offshore and “hide behind complex corporate structures”. 

Discussing clause 165, the shadow minister said: “Our concern… is about the chilling effect that a preliminary notice might have on a legitimate actor”. He explained that once a recipient receives a preliminary notice, they may choose to pre-emptively cut ties with somebody whom HMRC has flagged as a suspected promoter, even though a preliminary notice is not an official conclusion. That means that preliminary notices will require a lower threshold of evidence in comparison with a promoter action notice, with no judicial oversight. He referenced the technical consultation last year in which UK Finance raised the fact that this could affect financial institutions as well. 

The shadow minister noted that following the issuance of a preliminary notice or promoter action notice the process keeps the suspected promoter completely unaware. He suggested: “That potential overreach could have chilling effects on people whom HMRC merely suspects”. He urged the government to consider safeguards to protect legitimate actors. 

The Shadow XST intervened and asked if the Shadow Economic Secretary agreed with CIOT that 30 days preliminary notice is “inadequate”, observing: “A 90-day period is used for similar notices, such as follower notices or accelerated payment notices.” 

Garnier agreed, suggesting that: “If it takes more than 30 days on a regular basis to respond to such things, it is absolutely right that we would have longer time in order to help”. 

In regard to clause 167, the shadow minister cited the Association of Taxation Technicians (ATT), which had outlined the unfairness of notice recipients only being able “to address the technicalities of the arrangements, with no opportunity to have the wider picture taken into consideration”, given that promoters are able to challenge HMRC’s core allegations at a tribunal. He continued that the recipient may just be “an unwitting enabler”, unable to appeal the notice. He asked if the minister could outline how the government will ensure that individuals can appeal against the notices. 

Turning to clause 168 and civil penalties, Garnier suggested that the first-tier tribunal can take a significant amount of time and enquired - referencing concerns from the Association of Chartered Certified Accountants – whether HMRC has the resources to compensate for the increased workload. 

Reynolds, for the Lib Dems, asked whether the government will take action against offshore promoters. 

“The clause is a key one for going after promoters based offshore”, stated the XST. He said that this is why HMRC is taking this new approach with the promoter action notices, which sever the ability of promoters based overseas to have interactions and dealings with companies based in the UK. The minister quoted Tax Policy Associates, which had said that “any business targeting UK clients is inevitably going to rely on banks, social media etc in the UK—so it makes sense to enable HMRC to target [this].” 

The Shadow XST intervened to ask if the minister was indicating that such people would be blocked from using the banking system in the UK if they are served with one of the notices. The XST did not respond directly, saying only that “[o]ne of the big challenges with these promoters is that… they are based overseas make[ing] effective enforcement difficult” 

On the issue of appeals, the minister said: “It is important to note that promoter action notices are issued only towards the end of the line”. On what happens if businesses go further than HMRC’s request and end up severing all ties with promoters, the minister replied: “HMRC will specify the actions that need to be taken, but businesses may want to go further, at their own discretion and within the law”.  

Clauses 163-173 – passed  

Anti-avoidance information notices (definitions, types and requirements) (clauses 174 to 185) 

Clause 174: Connected persons 
Clause 175: Anti-avoidance enactments 
Clause 176: Information notices: connected persons 
Clause 177: Information notices: third parties 
Clause 178: Information notices: unidentified connected persons 
Clause 179: Information notices: identification 
Clause 180: Information notices: financial institutions 
Clause 181: Content and requirements of notices 
Clause 182: Restriction on disclosure of notices 
Clause 183: Excepted information 
Clause 184: Tribunal approval of notices 
Clause 185: Withdrawal of notices 

The XST told MPs that these new powers to issue anti-avoidance information notices would expand HMRC’s ability to assess compliance with obligations under HMRC’s powers, and to effectively investigate those who own and control promoter organisations.  

On clause 182, the Shadow Economic Secretary noted that CIOT recommends adding “making representations against the notice” to the circumstances in which someone may disclose a notice so they may access professional or legal advice. He labelled this a “sensible” recommendation and hoped that the minister would “see it as such and commit to looking at adding these words before the Bill returns on Report”.  

The shadow minister noted that clause 183 sets out which categories of information cannot be required under anti-avoidance notices, exempting legal advice but not advice provided by accountants or tax advisers. “That is despite the fact that a person would ask for advice on tax policy from an adviser or an accountant in the same manner that a person would ask for legal advice from a lawyer,” he observed. He said that without additional exemptions it could result in “people or entities being disincentivised from seeking advice from tax advisers or accountants based in the UK”.  He asked the minister to set out the rationale for protecting legally privileged material but not other types of advice, and to say whether the government would consider introducing changes to this clause to “level the playing field”. 

The XST replied that the government’s view is that the legislation provides “sufficient scope” for the recipient to be able to disclose information for legal advice. While “happy to consider” the shadow minister’s recommendations, he reported that he does not expect the government to introduce an amendment to the clause, because “we think that the clause is already sufficient”. 

Clauses 174 – 185 – passed 

Anti-avoidance information notices (sanctions and appeals) (clauses 186-205) 

Clause 186: Offence of failing to comply with a notice 
Clause 187: Offence of concealing information  
Clause 188: Criminal liability of responsible persons  
Clause 189: Criminal liability of responsible persons: no prosecution of recipient  
Clause 190: Imprisonment or a fine  
Clause 191: Penalty for failing to comply with a notice  
Clause 192: Penalty for concealing information  
Clause 193: Penalty for inaccurate information  
Clause 194: Penalty for disclosing a notice  
Clause 195: Penalty based on monies received  
Clause 196: Increased daily default penalty  
Clause 197: Extension of time periods  
Clause 198: Reasonable excuse  
Clause 199: Double jeopardy  
Clause 200: Assessment etc of penalties: application of Schedule 36 to FA 2008 
Clause 201: Appeals against notices  
Clause 202: Appeals against penalties 
Clause 203: Interpretation  
Clause 204: Application of provisions of TMA 1970  
Clause 205: Repeals  

The Shadow Economic Secretary said he was concerned that the government has not set out the threshold for HMRC to pursue a criminal conviction that would result in a prison sentence. He requested further clarity. 

The XST responded that the government has consulted “extensively” on these notices, adding that: “On prosecution, as well as the standards and safeguards set out in the Bill, for a prosecution to be brought against anyone it also has to meet the evidential tests and the public interest tests”. 

Clauses 186 – 205 – passed 

Legal professionals (clauses 206 to 212) 

Clause 206: Declaration in relation to privileged material  
Clause 207: Penalties for an incorrect declaration  
Clause 208: Penalties: procedure, appeals etc  
Clause 209: Publication following an incorrect declaration 
Clause 210: Time limits for publication  
Clause 211: Amendments to existing legislation: removal of legal professional privilege exemption   
Clause 212: Commencement 

The XST said that these clauses allow HMRC to publish the details of legal professionals involved in promoting tax avoidance schemes. Existing legislation prohibits this when the legal professional’s role is limited to activity subject to legal professional privilege, such as designing schemes. These clauses change that. 

The Shadow Economic Secretary supported what the clauses look to achieve and said “there is widespread agreement from those in industry about the positivity of the changes”. 

Clauses 206 – 212 – passed  

Disclosure of tax avoidance schemes: consequences for failure to comply (clauses 213 – 216) 

Clause 213: Penalties for non-disclosure of tax avoidance schemes 
Clause 214: Removal of time limits on publication by HMRC 
Clause 215: Consequential amendments  
Clause 216: Commencement 

The XST highlighted that these clauses grant HMRC the authority to assess penalties directly, rather than requiring an application to the tax tribunal for determination. There were no other speakers on these clauses. 

Clauses 213 – 216 – passed 

Construction industry scheme (CIS) amendments (clauses 217 to 219) 

Clause 217: Construction Industry Scheme: amendments 
Clause 218: Construction Industry Scheme regulations: amendments  
Clause 219: Commencement 

The XST said that these clauses would tackle supply chain fraud in the construction industry by enabling HMRC to act against businesses within supply chains that hold gross payment status and knowingly act as buffers between compliant businesses and fraudulent businesses that steal workers’ deductions.  

The Shadow Economic Secretary agreed that these clauses would help to streamline the process and allow HMRC to quickly cancel benefits where there is deliberate non-compliance or fraud. However, he said there is a “lack of clarity” that needs addressing. “We recognise that, in this instance, the terminology follows European Court of Justice and High Court judgments that established the Kittel principle, which means that a business that ‘should have known’ is aiding the perpetrators of fraud and is effectively an accomplice. However, there is no concrete definition of this term, and by extension there is a lack of clarity for innocent parties that make genuine errors”. 

The shadow minister suggested that if providing further clarity is not possible, it would be useful to understand how HMRC proposes to ensure that mistakes are not made in decision-making and whether it intends to publish any corresponding guidance for businesses and interested parties. 

The XST acknowledged the ‘important’ point that the shadow minister had raised, but said that the government’s view is that compliant businesses should not be “affected” by these changes, as they will already be undertaking the due diligence necessary to prevent them from engaging with fraudulent businesses. 

Clauses 217 – 219 – passed 

PART 7 – TAX ADVISERS 

Registration (prohibition and application process) (clauses 220 – 229 plus government amendments 16-19, 39 and 40) 

Clause 220 & Schedule 19: Prohibition against unregistered tax advisers interacting with HMRC 
Clause 221: Meaning of “tax adviser” and “client” 
Clause 222: Application for registration 
Clause 223: Meaning of “relevant individual” and “officer” 
Clause 224: Registration conditions  
Clause 225: Registration conditions: interpretation  
Clause 226 : Registration conditions: offences  
Clause 227: Registration of tax advisers etc 
Clause 228: Monitoring of registration conditions  
Clause 229: Suspension of registration  

Introducing these clauses the XST said that the government “have been engaging in detail with stakeholders on the changes we are making, because it is important that legitimate and good tax advisers see that the government have confidence in them and the work they are doing.” 

He explained that these clauses will require tax advisers who interact with HMRC on behalf of a client to register with HMRC and meet minimum standards from May 2026. “Anyone paid to interact with HMRC on behalf of clients—for example, by submitting tax returns or other information to HMRC—will fall within scope of the requirement to register.” 

“That is not the same as regulating tax advice,” he argued. “HMRC will not review the quality of the advice provided, qualifications or professional conduct. Instead, the measures are specifically about stopping harmful tax advisers who do not meet the basic minimum standards. At registration, tax advisers will be asked to confirm that they will meet HMRC’s standards for agents. The measures do not give HMRC new powers to investigate whether applicants breach the standard for agents, and registration would not be suspended if a minor breach is discovered.” 

Martin Wrigley (Lib Dem) questioned this claim. While acknowledging that HMRC is not a regulator that looks at the quality of tax advice, he thought that “it has every other aspect of a regulator that one might find. I used to work for a regulator in telecoms, and some of the powers in these measures are exactly what we had in that regulator. It is a regulator; although it does not regulate the quality of the advice, it still penalises. However, it has none of the mitigation factors that come with a regulator—the ability to appeal and to ensure that decisions that are being made are reasonable.” 

The minister disagreed. “The hon. gentleman makes the point that we will not review the quality of advice provided, but we also will not be stepping in to certify qualifications or professional conduct more broadly. The government have been listening to and engaging with the sector on these measures in recent months—indeed, I believe, over a long period—to make sure minimum standards are set out in the standards for agents. We want to ensure that there is a floor within the system so that agents meet [those] minimum standards.” 

The minister said that HMRC “will suspend a tax adviser only after due process, including offering opportunities to comply and a chance for the adviser to explain whether there is a good reason why they are unable to do so. HMRC will not use these powers for minor breaches.” 

He added that the six government amendments to these clauses are “to ensure that the legislation works as intended”. He explained: “Following discussions with stakeholders, the government have concluded that it is not proportionate to treat non-compliance with these regimes [Disclosure of Tax Avoidance Schemes and its VAT counterpart] differently from non-compliance with other information-gathering regimes.” 

The Shadow Economic Secretary began by recalling the retail distribution review which had taken place in 2011-12. This had required wealth managers to have “proper qualifications”, given them potentially unlimited liability and changed how they are compensated. The net result had been “a very significant drop-off in the number of people receiving advice, and… putting money into pensions… People are less prepared for their future, have less money put away for savings, and are generally more vulnerable: that is a direct result of a well-intentioned piece of legislation”. He said the Conservatives were worried about unintended consequences in this legislation. 

The shadow minister noted that organisations such as CIOT and ICAEW had shown support for the idea of registration. “However, there is a concern that this legislation is focused solely on interacting with HMRC, so keeps a significant section of the tax advice market out of scope. As the trade bodies point out, it is those who fall outside the scope of the measures who are historically responsible for some of the most egregious harm.” He asked the minister to set out any planned action against “that less reputable group”. 

He endorsed the proposal – put by CIOT – for a review of the impact of this measure and asked the minister to consider this. 

He was concerned that the registration conditions in clause 224 “[dp] not contain sufficient safeguards, nor a reasonable excuse defence for late filing or minor underpayment from a person. Under the Bill as drafted, a tax adviser could be suspended… for owing just £1 in tax.” He asked the minister to consider adding strong safeguards. 

He said clause 229, suspension of registration, “has caused significant concern to industry”. Clients could be detrimentally impacted through no fault of their own. “Could the Minister clarify how an innocent client will be protected when their tax adviser is suspended at late notice?” He also asked the minister to consider only allowing the HMRC commissioners to use the suspension power, rather than any ‘authorised officer’. 

Finally, he noted CIOT’s comment that, “the temporary relief [of suspension] provisions are at best difficult to navigate, and in some cases not available.” “Firms could be suspended and forced to stop advising clients, only for their suspension decision to be later overturned,” he worried. He asked the minister to commit to two actions “first, requiring HMRC to publish guidance for tax advisers and relevant individuals about navigating the suspension process; and secondly, writing to the Committee about removing the temporary relief from suspension and replacing it with an automatic pause for suspension while a review or appeal is ongoing.” 

Joshua Reynolds, for the Lib Dems, noted that ICAEW had called these clauses “existential” for adviser firms. Like Mark Garnier, he worried that “[s]uspension of a reputable firm could force that firm to cease trading, only for the decision to be overturned a few days later because it was a genuine mistake.” This could happen for as little as £1. 

He continued: “I would like to see the minister consider a statutory proportionality test to HMRC for the suspension powers, because these business-ending sanctions need proportionality. The idea that a £1 mistake could cost someone their livelihood and their family their home is not proportionate in any way.” 

Responding, the XST sought “to offer reassurance that HMRC will suspend an adviser only after due process has been followed, including offering opportunities to comply and a chance for the adviser to explain if there is a good reason why they are unable to do so. I think that is reasonable and proportionate.”  

Reynolds challenged the minister that the legislation appears to be clear that any money owing to HMRC – even just £1 – means a suspension. The minister replied “that HMRC will suspend a tax adviser only after due process, including after offering opportunities to comply and a chance for the adviser to explain if there was a good reason why they were unable to do so.” 

Regarding the impact on tax advisers, and whether it would be expensive or burdensome, the minister stressed that HMRC will not be charging for registration, and that many tax advisers will already have an agent services account. “Those that do will be moved automatically on to the new system, and will not have to re-register. HMRC will use automatic checks to ensure that the process is as quick and easy as possible for applicants.” The minister said the government “want to see a thriving and growing accountancy and tax advice market in the UK”.  

The Shadow XST noted the ATT’s point “that the scheme is due to be a requirement from May, yet there is a lack of clarity about how or when advisers need to register”. The minister replied that the imminence of the change was “why it is really important to get the guidance published very soon, and I will be working with officials on that. It will be published in the coming weeks, to give advisers time to prepare.” 

Clauses 220 – 229 plus government amendments 16-19, 39 and 40, passed. 

Registration (compliance notice, penalties, etc) (clauses 230 – 237)  

Clause 230: Compliance notice 
Clause 231: Financial penalties for prohibited interaction with HMRC 
Clause 232: Financial penalties for prohibited interaction with HMRC: liability of relevant individuals 
Clause 233: Tax advisers: ineligibility orders  
Clause 234: Relevant individuals: ineligibility orders 
Clause 235: Requirement for tax adviser to notify clients of suspension or ineligibility orders   
Clause 236: Summary 
Clause 237: Extension of period for making representations 

The XST reiterated that HMRC “will always work with a tax adviser who is genuinely trying to comply, will never suspend a tax adviser when doing so would be unreasonable or disproportionate, and will always consider the nature of any potential breach and how a suspension would impact the tax adviser and their clients”.  

The Shadow Economic Secretary said, citing ICAEW representations, that there should be time requirements on HMRC for notifying an adviser of a compliance notice. He asked for clarity that ineligibility orders will be issued in a reasonable manner, and for a mechanism for an ineligibility order to be cancelled if an appeal or a review finds in favour of the tax adviser. Also, the suspension or ineligibility orders “should only apply once an order is final… [I]t would be unfair on a business to notify clients of an order to only then have it withdrawn.”  

Responding, the XST said he would take the point around timelines and HMRC promptness away and come back to the shadow minister if there is more detail that can be provided. 

Clauses 230 – 237 passed. 

Registration (assessment of financial penalties) (clauses 238-240)  

Clause 238: Assessment of financial penalties 
Clause 239: Time limits and treatment of financial penalties   
Clause 240: Double jeopardy  

These clauses were dealt with briefly, with the XST the only speaker. He said the clauses place limits on how long HMRC may delay before applying a penalty. 

Clauses 238-240 passed. 

Reviews and appeals (clause 241 & schedule 20) 

Clause 241 & Schedule 20: Reviews and appeals  

The XST told MPs that this clause and schedule set out the details of reviews and appeals in relation to tax adviser registration. Questioned by Martin Wrigley he said the tribunal to which advisers may appeal “will be independent to the extent that those officers who made decisions and any determinations about the matter will not be involved in the tribunal”.  

He explained that temporary relief, which delays the application of a sanction while there is an appeal or it is subject to review, will always be granted “when the suspension is just due to late tax returns or payments, and [HMRC] will always consider whether not granting relief would put a business at risk of failing before it had been able to appeal”.  

The Shadow Economic Secretary observed that paragraph 6 of the schedule provides that a statutory review automatically concludes in HMRC’s favour if it fails to deal with the review request. “As the Chartered Institute of Taxation puts it, that ‘seems particularly inappropriate here, given an appeal is one of the few ways that a firm can challenge this regulatory decision (in which HMRC has a conflict of interest).’” He agreed, and asked the minister to consider removing paragraph 6(7). 

He was also concerned that the decision to grant temporary relief “rests with an individual authorised HMRC officer, who can be the same officer who issued the suspension.” Also the officer must take into account the prospect of the review or appeal succeeding. He worried that might create conflicts of interest and be unfair to the applicant. 

Wrigley recalled his experience on a tribunal for the Phone-paid Services Authority: “That tribunal was headed by a senior barrister, with two lay members who did not work for the executive and were fully independent.” He continued: “I do not see something similar in schedule 20, and this is a considerably more important piece of work.” Would the minister look again at the composition of the tribunal to ensure that it is not equivalent officers, but truly independent persons, preferably from outside HMRC, who are making decisions, he asked. 

The XST replied that the tribunal is independent and its head would be an existing first-tier tax tribunal judge. But he offered to write to Wrigley in more detail on the composition and independence of the tribunal. He said the government would not be removing paragraph 6(7), but did not explain why. 

Clause 241 & schedule 20 passed. 

Safeguards (clauses 242 – 246)  

Clause 242: Disclosure of information  
Clause 243: Power to publish information  
Clause 244 & Schedule 19 : Power to amend Schedule 19 (exceptions)  
Clause 245: Interpretation of Chapter  
Clause 246: Commencement 

Debating these clauses the Shadow Economic Secretary was concerned that the commencement date will be May this year: “Although they have pushed this back by a month, are the government not concerned that this is an insufficient length of time for tax advisers to register?” This was what the industry had told him. “[I]s HMRC fully equipped to take on this extra workload,” he asked. “It is important that we get this right and that people have time to prepare.” 

The XST replied that while registration comes in from 18 May, it will be phased in over 2026-27 and tax advisers will have a minimum of three months to register. Most will have more time, he added. The shadow minister pressed for more information on this process but the minister just repeated that registration will be phased in during 2026-27.  

Clauses 242 – 246 passed. 

Conduct etc (clauses 247 to 250 plus amendment 25) 

Clause 247 & Schedule 21: Conduct of tax advisers 
Clause 248: Power to publish information 
Clause 249: Power to publish information: change of circumstances 
Clause 250: Power to publish information: interpretation and commencement 

The https://hansard.parliament.uk/search/MemberContributions?house=Commons&memberId=5282XST explained that this set of clauses strengthen HMRC’s powers to gather information and sanction dishonest tax advisers, and introduce a new power to allow HMRC to publish details of tax advisers who have been suspended or barred by HMRC from acting for clients where it is in the public interest to do so. 

He was at pains to emphasise that there will be a high threshold for use of the powers: “[they] will apply only to tax advisers who act with the intention of bringing about a loss of tax revenue, such as those who knowingly claim a tax repayment for a client who is not entitled to it or advise a client to deliberately enter incorrect figures on a tax return.” The powers “will not affect advisers who act in good faith, or who take a credible view as to what the law requires of their clients, including where they use extra-statutory concessions or HMRC guidance to form that view. They also do not affect advisers who make mistakes while trying… to do the right thing.”  

Amendment 25 was, the minister explained, just to correct a drafting error. 

The new publication power in clauses 248-250 will enable taxpayers to make more informed choices when selecting a tax adviser to represent them, the minister told the committee. “Taxpayers will be made aware of which advisers face restrictions when interacting with HMRC, which will help to increase transparency and trust.”  

The Shadow Economic Secretary began his remarks by noting the change from “dishonest conduct” rules to “sanctionable conduct” rules in schedule 21: “That may seem like a minor change, but it changes the current high threshold of dishonesty to one that is lower and potentially ambiguous.” This had been criticised by both ICAEW and CIOT he observed. 

CIOT had, he said, pointed out that the objective of the government’s policy is to target deliberate behaviour. “This change seems inadvertently to miss that objective entirely,” he argued, calling it “the wrong move” and noting “significant strength of feeling in the industry that the terminology should revert to its original wording”. He asked the minister to “commit to engaging further with industry stakeholders before report stage, and to making the necessary changes to accomplish the well-intentioned aim of the policy”. 

Joshua Reynolds, for the Lib Dems, had a similar concern. “Moving from ‘dishonest conduct’ to ‘sanctionable conduct’ lowers the threshold, introduces more ambiguity and could catch technical differences and genuine errors rather than deliberate wrongdoing,” he commented, adding that “these are real concerns shared by the Chartered Institute of Taxation and others. Their minds were not set at ease having read the Bill, so we must push these points today.” He urged the minister to consider a statutory proportionality test. 

The XST agreed that the difference between sanctionable conduct and dishonest conduct is an important question. He thought the Bill provided “more certainty and clarity, because instead of having to prove dishonesty, which is challenging, HMRC will now simply need to demonstrate… that an adviser has acted with the intention to cause a tax loss.” Objective dishonesty is “quite challenging to prove”, he added.  

On engagement he said that the government have engaged with stakeholders, at official and ministerial levels, on these clauses and others and he will continue to do so, adding that those stakeholders “are an important part of the tax and advice ecosystem and provide strong representation on behalf of their members”. He continued: “I thank them and their members for their work in supporting people to get their tax right and to comply with the tax code”. 

Clauses 247 to 250 plus amendment 25 passed 

PART 8 - MISCELLANEOUS AND FINAL 

Fiscal mandate assessments prepared by the Office for Budget Responsibility (clause 251) 

Moving to the final Part of the Bill, the Economic Secretary told MPs that this clause would improve the fiscal cycle in support of the government’s commitment to having just one major annual fiscal event. (Although the minister did not mention it, the single annual fiscal event was a recommendation in the 2017 Better Budgets report published by CIOT, the Institute for Government and the Institute for Fiscal Studies, adopted at the time by then Chancellor Philip Hammond, though since somewhat lapsed.) Specifically, she explained, this clause will reduce the minimum number of occasions on which the OBR must prepare an assessment of performance against the fiscal rules from two to one in each financial year.  

The Shadow Economic Secretary said this was a “terrible idea”. “The Office for Budget Responsibility is there to mark the homework of the Government. To reduce that homework marking to just once a year… is not a good idea.” 

Clause 251 passed. 

Provision of data by third parties (clauses 252 & schedule 22) 

This clause and schedule introduce new provisions for HMRC to acquire improved data from specific data holders to be used for risk assessment, tax administration and compliance, said the Economic Secretary. This improved data “will help taxpayers to get their tax right first time while closing the tax gap.” 

The Shadow Economic Secretary supported the measure, saying that, “[a]s we go into a more digital world, it is perfectly acceptable that people should be required to interact with HMRC online.” However, “not everybody is as computer literate, so what measures will be in place to support people if they are genuinely struggling?” 

Lib Dem Martin Wrigley was more concerned, saying the minister’s introductory remarks to this measure did not relate to the words in the Bill. Rather than giving a power where HMRC suspects wrongdoing, “it simply says that HMRC can demand any data from any of its customers at any time, on an ongoing basis.” “Unless I have completely misunderstood… that is not only draconian and arbitrary, but disproportionate”. He added that if HMRC is asking for all the data, it is going against the General Data Protection Regulation. 

The Economic Secretary replied that HMRC already receives bulk data from third parties relating to interest-bearing products and card sales data from card-acquiring services. She continued that this measure will improve and modernise the way HMRC acquires that data from third parties. She further assured Wrigley that the government take data privacy “extremely seriously” and this measure is compliant with all legal data obligations. 

Clause 252 & Schedule 22 – passed  

Making tax digital (clauses 253 – 258) 

Clause 253: Persons on whom digital reporting requirements may be imposed  
Clause 254: Exemptions from digital reporting requirements 
Clause 255: Returns to be delivered by electronic communications etc 
Clause 256: Penalties: amendments consequential on section 255 etc 
Clause 257: Powers relating to electronic communications: directions 
Clause 258: Power to require digital contact details 

The Economic Secretary told MPs that clauses 253 to 256 amend existing legislation to digitalise and improve the accuracy of tax reporting through HMRC’s Making Tax Digital for income tax programme. Meanwhile clauses 257 and 258 make changes to enable HMRC to modernise how it communicates with customers digitally. 

The Shadow Economic Secretary suggested that these clauses are all “fairly straightforward”, but on clause 258 raised an ATT concern that the proposed £1,000 penalty for failing to keep digital contact details up to date is “unprecedented and disproportionate”. He continued that there is no comparable HMRC penalty for failing to update a postal address or traditional form of contact. He urged the government to review whether £1,000 was “too high”  

Reynolds, stressing the importance of HMRC customer service phone lines, said that the Liberal Democrats would like to see a new ‘retiree red phone’ set up in HMRC, so that pensioners know that if they phone HMRC, they will get their call picked up as a priority. 

The Economic Secretary recognised the concern for digitally excluded individuals, reassuring them that safeguards will be included with support through non-digital channels. 

Clause 253 – 258 – passed  

Penalties (clause 259 – 262 plus amendment 50) 

Clause 259: Penalty points and late submission penalties (power to cancel etc) 
Clause 260: Assessments of late payment penalties etc. 
Clause 261: Penalties for failure to pay tax due on further appeal 
Clause 262: Failure to deliver company tax returns 

The Shadow XST, citing Tax Policy Associates, suggested that over the past five years, HMRC has issued about 600,000 late filing penalties to people whose incomes were “too low to owe any tax at all”. He stated: “Clearly, the system is not functioning as intended”. He believed that collectively, these clauses show an attempt to tighten compliance, but said “if no tax is due, no penalty should be charged, and that is what amendment 50 would deliver”.  

Reynolds, for the Lib Dems, backed the Shadow XST and said that amendment 50 showed “very good timing” as HMRC has revealed [on 3 February] its estimate that one million people missed the deadline to file their self-assessment returns. He added: “It is fair and proportionate that the penalty should focus on those avoiding tax obligations, and not penalising administrative delays when no tax is owed”. 

The Economic Secretary rejected amendment 50, saying that: “The late submission penalty regime is intended to underpin the legal obligation to submit returns on time, whether there is tax to be paid or not, and amendment 50 is entirely contrary to that intention”. 

Division: Amendment 50 defeated 11-6. 

Clauses 259 – 262 - passed 

Advance tax clearances (clauses 263 – 271) 

Clause 263: Clearances 
Clause 264: Binding effect 
Clause 265: Extension 
Clause 266: Modification 
Clause 267: Information 
Clause 268: Misrepresentation 
Clause 269: Commissioners notice 
Clause 270: Powers  
Clause 271: Interpretation 

The Economic Secretary explained that these clauses introduce an advance tax certainty service for major investment projects, which will be launched in July 2026. She continued that the service will provide a binding decision on how the UK’s tax rules will apply to a project before material investment has taken place. 

The Shadow XST agreed that this represents “useful steps towards greater tax certainty” for investors. However, on clause 264 which sets out the binding nature of the clearances he expressed concern: “Given that the purpose is to incentivise people to get on with investments and have certainty in advance of a project, will the minister explain how multiple extensions could be appropriate, when that could appear to frustrate the ambition to get shovels in the ground?” 

The minister replied that there is no limit on the number of extensions that can be sought or granted. 

Clauses 263 – 271 passed. 

Cryptoassets (clauses 272-273) 

Clause 272: Cryptoasset reporting: users and controlling persons resident in the UK 
Clause 273: International cryptoasset reporting framework: connected matters 

The Economic Secretary explained that these clauses would ensure that HMRC receives information under the cryptoasset reporting framework from UK cryptoasset businesses about their UK-resident customers.  

The Shadow Economic Secretary thought the ‘general thrust’ of the proposals a good idea. He noted that the clauses followed a recent Delegated Legislation Committee debate that he and the minister had attended, “as a result of which we are going to get together with some members of the industry to talk about the confusion on this issue. One thing that worries me about the clauses is that they fail to differentiate between a cryptoasset and a stablecoin or tokenised currency. It is important to recognise that those are two different things.” 

The Economic Secretary said stablecoins are cryptoassets for the purposes of the legislation. “Clarification on these matters has been reflected in HMRC guidance,” she assured the committee. 

Clauses 272-273 passed. 

Miscellaneous and Final (clauses 274-279) 

Clause 274: Stamp duty: piloting of digital service etc 
Clause 275: Oversight of HMRC tax enforcement functions in Northern Ireland 
Clause 276: Repeal of obsolete provision in FA 1925 concerning Dominion Governments 
Clause 277: Repeal of other obsolete provisions and correction of wrong cross-references 
Clause 278: Interpretation 
Clause 279: Short title 

The XST explained that as part of changes under the stamp taxes on shares modernisation project, stamp duty and stamp duty reserve tax will be replaced by the securities transfer charge. Clause 274 gives the government the power to make regulations to enable testing of a new digital service for this charge.  

Moving to clause 275 he said that, unlike other parts of the UK, there is currently no external, independent oversight of HMRC enforcement activities in Northern Ireland. This clause will change that by enabling HMRC to enter into an agreement with the Police Ombudsman for Northern Ireland to provide this. 

The Shadow XST supported clause 274 and the “sensible modernisation work” which, he noted, began under the previous government. Similarly, extending the oversight in clause 275 is “clearly sensible”. 

Clauses 274-279 passed. 

New Clauses 

At the end of the committee stage, MPs considered the new clauses (NC) tabled to the Bill. Some of these had already been debated, so all that remained was to move/call them (or not) for a vote.  

Conservative NC1, which would require a report on the impact of section 15 on early-stage investment volumes, investor participation and the UK’s international competitiveness, was not called. 

Conservative NC2, which would require a report on the impact of section 28 on business investment, employment in capital-intensive sectors, the manufacturing sector, small and medium-sized enterprises and the public finances, was voted on and defeated 10-6. 

Conservative NC3, which would require a review and report on the impact of the expiry in 2027 of the 100% allowance made under section 30, including the case for ongoing capital allowance support for zero-emission cars and electric vehicle charging points, was not called. 

Conservative NC4, which would require a report on the impact of section 48 on cross-border trade and business administrative burdens, and to set out how affected businesses and stakeholders will be consulted, was not called. 

Conservative NC5, which would require regular reviews of the implementation of section 50 and Schedule 8, including consideration of international implementation of Pillar Two, any competitive disadvantage for UK-based multinationals and possible remedial measures, was not called. 

Conservative NC6, which would require a report on the impact of section 52 on charitable giving through estates and on the income of the charity sector, was not called. 

Conservative NC7, which would require a report on the impact of section 53 on charity investment strategies, was not called. 

Conservative NC8, which would require a report on the impact of section 54 and Schedule 9 on legitimate charitable giving and the prevention of tax avoidance, was not called. 

Conservative NC9, which would require a review of the implementation of the outcome test in section 54 to assess whether it is clearer and more effective than the existing purpose test, was not called. 

Conservative NC10, which would require a report on the impact of uprating the winter fuel payment charge cap in line with the consumer prices index on liable households and on Exchequer receipts, was voted on and defeated 10-6. 

Conservative NC11, would require a report on the impact of section 56 on the UK’s ability to attract and retain fund managers, on investment into the UK and on realised revenues compared with forecasts, was not called. 

Conservative NC12, which would require a report on the impact of section 61 on North Sea decommissioning, employment and capital expenditure in the UK oil and gas industry, UK production and demand, and the Scottish economy, was not called. 

Conservative NC13, which would require a report on the impact of section 75 on charitable donations, the finances of charities and registered clubs, donor behaviour and Exchequer revenues, was not called. 

Conservative NC14, which would require a report on the impact of section 79 on the taxi and private hire industry, driver earnings, vulnerable passengers, rural communities and passenger fares, was not called 

Conservative NC15, which would require a report on the potential benefits of extending beyond three years the period for which UK listing relief applies under section 82, including effects on the attractiveness of UK markets, capital raising and Exchequer revenues, was not called 

Conservative NC17, which would require the Chancellor to make a statement on the impact of the increase to vehicle excise duty under section 89 on the automotive sector, household incomes and the UK economy, was not called. 

Conservative NC18, which would require the Chancellor to make a statement on the increases to HGV vehicle excise duty under sections 90 to 93 and to the HGV Road User Levy under section 95, including their impact on the haulage sector, decarbonisation of logistics and the UK economy, was not called. 

Conservative NC19, which would require a report on the impact of section 94 on the automotive sector, sales of hybrid cars and vehicle excise duty revenues from high-value vehicles, and to consider whether the threshold remains appropriate, was not called 

Conservative NC20, which would require an assessment of the impact of changes to air passenger duty under section 96 on the aviation industry, passengers, household finances at different income levels, and the public finances, was not called. 

Conservative NC21, which would require a report on the impact of section 97 on energy-intensive industries and the UK’s international competitiveness, was not called. 

Conservative NC22, which would require a report on the impact of section 98, including any effects on construction and infrastructure projects, port investment, recycling and illegal dumping, progress towards environmental objectives and Exchequer revenues, was voted on and defeated 10-6. 

Conservative NC23, which would require a report on the impact of section 99 on the construction industry and infrastructure projects, was not called. 

Conservative NC24, which would require a report on the impact of section 13 on recruitment and retention in qualifying companies, on high-growth and innovative businesses, and on the Exchequer finances, was not called. 

Lib Dem NC25, which would require HMRC to report on the operation and fairness of the new loan charge settlement opportunity, was voted on and defeated 10-6. 

Lib Dem NC26, which would require HMRC to report on the exclusion from the new loan charge settlement opportunity of disguised remuneration arrangements outside the loan charge years, including arrangements which HMRC considers to fall outside the loan charge but within the disguised remuneration rules, was not called. 

Lib Dem NC27, which would require HMRC to report on the operation of the winter fuel payment charge, including its effect on people whose income exceeds the threshold by a small amount, was voted on and defeated 10-6. 

Lib Dem NC28, which would require HMRC to assess the potential benefits of establishing a digital application process for taxpayers to pay capital gains tax by instalments in respect of disposal to employee ownership trusts as part of the implementation of section 35, was not called. 

Lib Dem NC29, which would require a report on the impact of section 35 on small and medium-sized enterprises, was not called. 

Conservative NC31, which would require an assessment of the impact of sections 87 and 88 on the illicit tobacco market, was not called. 

Conservative NC32 on air passenger duty change on boarding passes was not called. 

Conservative NC33 and NC35, which require a review of the effects of the Bill as a whole on business, were moved by the Shadow XST, who described them as “necessary”. He explained that: “We have heard a common theme in Committee that the Bill places yet more strain and burden on businesses already facing a difficult economic climate. It is stuffed full of tax increases”. He continued it is important that ministers “stop, listen and take account of the wider effects and headwinds that people are facing”. 

While rejecting these new clauses, the XST said the government’s view is that these new clauses would “largely duplicate work that is already undertaken and add unnecessary reporting burdens and costs”. NC33 and NC35 were withdrawn. 

Conservative NC34, which requires a review of the impact of tax changes in the Bill on households, was also moved by the Shadow XST. He suggested this new clause would “shine a light on the real impact on ordinary families of the government’s choices”. In response, the XST criticised the Conservative government's record on living standards, claiming that wages have increased faster than they did in the first 10 years under the Conservatives. NC34 was also withdrawn. 

Additionally, Conservative NC36, which would require the Chancellor to review and report on the effects of the Act on the administrative burden on businesses, including the impact on SMEs and any mitigation measures, was debated. The Shadow XST stated: “As is so often the case with this government, there is a big gap between what they promise and what they deliver”. He emphasised the need for a clear assessment of the Bill’s impact on the administrative burden facing businesses.  

While thanking all members of the committee, the XST said that the Bill helps the government to make progress with their priorities in the funding of public services, 

The Shadow XST also thanked CIOT, ATT and many other organisations that provided valuable submissions on the provisions of the Bill. 

Next stage 

The date for the Report stage of the Bill has not been set yet, but it will not take place before the week starting 23 February.