Open Consultations

We are frequently invited to comment on matters of tax law or practice, and we also submit proactive papers to Government where we feel there are issues to be raised or we wish to stimulate discussion. This section lists open consultations on which we would welcome input. Have your say on consultations here.

All our submissions are available to view here.

On 28 April 2020 the Financial Secretary to the Treasury provided a comprehensive update on tax policy documents. As well as highlighting those consultations where the response date has been extended by three months, it also includes confirmation that some documents announced at Budget 2020 would be published on a case by case basis, and that the government will delay the publication of a number of documents until the autumn.


The government has issued a Business Rates Review: Call for Evidence following the commitment in the Spring 2020 Budget to conduct a fundamental review of the business rates system in England. The call for evidence is in two tranches. The first tranche concerns reliefs and the multiplier. 

On L-Day, the government published draft clauses to help tackle the hidden economy which introduce a check on tax registration (‘conditionality’) for applications made by individuals, companies and partnerships (including LLPs) for licences to drive taxis and / or private hire vehicles (PHVs), operate a PHV business or deal in scrap metal from 4 April 2022.  This includes the following new measures:

Following the announcement at the Budget in March that the government would delay the implementation of the PAYE cap on the payable tax credit in the SME R&D scheme until 1 April 2021, the government published a Summary of responses to last years’ consultation and a Second consultation.

On L-Day, the government published a consultation exploring the scope of qualifying expenditure for R&D tax credits, which was trailed at the Budget.  Specifically, the consultation is looking at whether expenditures on data and cloud computing ought to qualify for relief. The consultation document adds that the government is not inviting views on the internationally agreed definition of R&D itself. 

HM Treasury has published a response to the consultation last year on introducing an SDLT surcharge for non-UK resident purchasers of residential property

On L-Day the government published a call for evidence to consider the principles and design of a new Stamp Duty and SDRT Framework, which is intended to inform a longer-term modernisation of Stamp Duty and SDRT.  The government is seeking views on what should be the principles and design of a new framework for taxing shares and securities and what should be prioritised in any modernisation programme. 

On L-Day, the government published draft clauses which amend HMRC’s civil information power by: 

This measure introduces proposals to tackle promoters (and other enablers) of tax avoidance schemes that would reduce the scope for promoters (and other enablers) to market tax avoidance schemes.

On L-Day, the government published draft clauses to make a series of changes to existing tax avoidance legislation, alongside a consultation document which contains a series of detailed questions.  The proposals are designed to strengthen the existing regimes and to change the behaviour of those involved in promoting and enabling tax avoidance schemes.

The government has published a consultation on 'Tackling Construction Industry Scheme abuse'.