Tax advisory market and draft Finance Bill 2025-26 legislation – Law Society response

27 Nov 2025

2 minutes read

The UK government’s proposals for the Finance Bill 2025-26 are too far-reaching and risk adversely impacting the public’s access to affordable and high-quality tax advice.

Any changes introduced by the UK government should be proportionate and consider the regulations and standards that professionals are already subject to.

Learn about the proposed changes and how these would impact the tax advisory market.

Our view

As the professional body for solicitors, we amplify the powerful collective voice of more than 200,000 solicitors, advocating on the issues you’ve told us matter most.

Tax advisers, many of whom are solicitors, are essential in assisting taxpayers to navigate the complexities of the tax system. They are HMRC’s first line of defence against non-compliance.

The UK government’s proposals to the Finance Bill 2025-26 are too far-reaching.

We hold serious concerns that the proposals will discourage tax advisers from entering or remaining in the tax advisory market.

This will make it harder for taxpayers to get affordable, high-quality tax advice.

What we’re doing

We’re working hard to influence the government and make sure our members’ views and challenges are heard.

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In October 2025, we responded to the government’s consultation on closing in on promoters of marketed tax avoidance.

The consultation proposed that it would become a strict liability criminal offence to fail to disclose under:

disclosure of tax avoidance schemes (DOTAS), or
disclosure of tax avoidance schemes: VAT and other indirect taxes (DASVOIT)

We support the government’s aim to target the promoters of marketed tax avoidance.

However, the broad, and at times uncertain, basis for a disclosure obligation will bring many tax advisers within scope of a criminal offence.

We raised concerns about the:

disproportionate and inappropriate criminal offences
workability of the declaration in relation to legally privileged material
scope of the Universal Stop Regulations
need for guidance and stronger safeguards for promoter action notices (PANs)

Download our full response on promotors of marketed tax avoidance (PDF 423 KB).

In September 2025, we responded to the government’s proposals to enhance HMRC’s powers.

The proposals aim to strengthen HMRC’s powers to act more quickly and firmly against tax advisers who enable client non-compliance.

We support HMRC’s view that there is no place for tax advisers who intend to harm the tax system. However, it is critical that the steps taken to stop this small number of advisers do not deter others from the tax advice market.

We raised concerns about the:

imprecise scope and definitions of
low threshold for a file access notice
proposed penalties based on potential lost revenue
insufficient safeguards for the power to publish information about a tax agent

Download our full response on enhancing HMRC’s powers (PDF 244 KB)/

In September 2025, we responded to the government’s consultation on modernising and mandating tax adviser registration with HMRC.

The consultation proposes a legal requirement for tax advisers.

Tax advisers who interact with HMRC on behalf of clients must register with HMRC and meet minimum standards

We agree with the government’s objective to raise the standards of tax advisers. However, the proposals are too broad.

Any changes introduced by the UK government should be proportionate and account for the existing framework of the Solicitors Regulation Authority (SRA).

We raised concerns about the: