HMRC Stakeholder Conference

HMRC held its 2025 Stakeholder Conference in London on 16 September 2025, combining speeches from senior government and HMRC officials with a question and answer session, as well as workshops on a range of issues, including Making Tax Digital (MTD) for income tax. 

There was also a surprise, but very welcome, recognition of the work done by Caroline Miskin, who led on MTD for income tax for ICAEW up until her retirement in August 2025. Caroline was thanked for vigorously challenging HMRC in a positive way by Jonathan Athow, HMRC Director General Customer Strategy and Tax Design, in his speech to the conference.

Read more about the conference

Promoters, raising standards and mandatory registration of agents

While ICAEW has always supported the objective of driving bad actors out of the tax advice market through properly targeted measures, it has serious concerns about the three sets of measures published on L-Day that impact on tax agents. Taken together, these measures risk having a damaging impact on business growth and the potential to undermine, rather than improve, tax compliance. The faculty has now expressed these views in its representations submitted on 15 September.

ICAEW’s Tax Policy & Reputation Committee continues to be actively engaged to push the need for changes to the draft legislation and we hope for further meetings with HMRC and the new Exchequer Secretary, Dan Tomlinson. 

Learn more about the faculty’s concerns

Draft Finance Bill legislation 

In addition to the three sets of draft legislation affecting agents as set out above, the Tax Faculty also responded on a number of other measures. These are listed in the tax representations below but particular responses to note include the proposed inclusion of unused pensions in the estate subject to inheritance tax and the changes to agricultural and business property relief. In respect of the former, our feedback was that the proposed approach was unworkable and could result in significant risks for personal representatives of the estate who might be forced to try and recover funds already paid out without deduction to pensions beneficiaries. We had a constructive meeting with HMRC to consider how the arrangements could be improved in order to ensure fairness across all the estate and pensions beneficiaries.

Find out more about ICAEW’s concerns

Meetings with HMRC

During the month ICAEW attended a number of meetings with HMRC, some in conjunction with other representative bodies. These included: the One-To-Many Compliance Advisory Board; the Making Tax Digital External Readiness Forum; and the Employment and Payroll Group.

HMRC service standards

Although there are some signs that HMRC’s service levels may have improved, members continue to report lengthy delays, especially in the area of tax repayments where delays of eight months have been reported. ICAEW continues to press HMRC to speed up tax repayments as the current situation is not acceptable. On 23 September, Tax Faculty staff and representatives from other professional bodies attended a visit to HMRC’s offices in Portsmouth to see at first-hand how a major HMRC office operates. The visit also included a meeting of CSTARB, the new forum for the representative bodies to discuss tax service matters with HMRC. At that meeting, HMRC noted that there will be an article in next month’s agent update with a list of top tips to make sure that such claims are not rejected.

Engagement with HMRC on its guidance for ESC D32 – update

Together with the Chartered Institute of Taxation, we are engaging with HMRC in relation to uncertainties in the application of ESC D32 and how those uncertainties might be addressed in the guidance in the Capital Gains manual. Updated draft guidance for CG65745 is currently under consideration. As part of these discussions, HMRC has confirmed that although all extra-statutory concessions are kept under review, there is no intention to withdraw ESC D32 at this time.

Professional conduct

The seven bodies that comprise the Professional Conduct in Relation to Taxation (PCRT) group have now finalised the changes to the PCRT following the publication of IESBA’s Tax Planning and Related Services code. The revised PCRT will be published on 1 October 2025 with a start date of 1 January 2026. We plan to produce a supporting webinar in due course. The PCRT group continue to work on topical guidance on R&D, AI and MTD. Once these are completed the group will turn its attention to revising the Helpsheets that accompany the PCRT. As part of this work, we engaged extensively with the other PCRT bodies and also ethics colleagues in ICAEW and the CCAB. 

Tax Faculty and other meetings

Meetings held during the month included: the Tax Faculty Board, the Practitioners’ Tax Committee; the Tax Policy and Reputation Committee; and the Compliance and Investigations Committee. 

Representations and TAXguides

We submitted the following representations:

• ICAEW REP 73/25 Policy paper Income Tax — changes to Employee Car Ownership Schemes

• ICAEW REP 72/25 Policy paper better use of new and improved third-party data

• ICAEW REP 71/25 Policy paper Proposals to close in on promoters of marketed tax avoidance

• ICAEW REP 70/25 Policy paper Enhancing HMRC’s powers: tackling tax adviser facilitated non-compliance

• ICAEW REP 69/25 Policy paper Modernising and mandating tax adviser registration with HMRC

• ICAEW REP 67/25 Reforming inheritance tax - unused pension funds and death benefits

• ICAEW REP 68/25 Reforming agricultural property relief (APR) and business property relief (BPR)

• ICAEW REP 66/25 Land remediation relief consultation

• ICAEW REP 65/25 making tax digital for income tax and penalty reform

• ICAEW Representation 62/25 Changes to charity compliance measures

Faculty webinars, events and podcasts

Our monthly podcast series, The Tax Track, continues to gather new listeners and get good feedback and engagement. In the latest episode, Lindsey Wicks, Senior Technical Manager – Tax Policy and technical managers Katherine Ford and Stephen Relf talked about our concerns with regard to the draft Finance Bill legislation that directly affects agents (see above) and highlighted some of the challenging areas for tax returns for 2024/25. 

Media activity

The Financial Times referred to a news item published by ICAEW in an article on 2024/25 tax return issues related to the mid-year change in CGT rates. The Times quoted comments from Katherine Ford in an article on the same topic. 

Katherine Ford was also quoted by the Birmingham Mail on the 15 September 2025 deadline for pensioners in parts of the UK to opt out of receiving winter fuel payments.