In August 2026, HM Treasury invited stakeholder representations ahead of the 2026 Autumn Budget. We take a look at the representations made by some of the professional bodies.
The Budget on 28 October 2026 will be the first delivered by the new Chancellor, John Healey, under the new Prime Minister, Andy Burnham. The representations process gives professional bodies the chance to comment on current government policies and suggest possible changes before the Budget.
Several professional bodies in the tax and accounting sector have published their representations. We have summarised some of them below.
The Association of Taxation Technicians (ATT)
The ATT published six representations this year, including on Inheritance Tax (IHT) simplification, Making Tax Digital (MTD) penalties and HMRC-approved mileage rates. Its recommendations were:
- Simplification of the IHT regime to bring a fairer system for those affected:
- The Nil Rate Band (NRB) and the Residence Nil Rate Band (RNRB) should be merged into one single enhanced NRB. As unused pensions come into scope for IHT from April 2027, this would avoid more families having to 'grapple' with the complexities of the RNRB.
- Pension property should be treated as a separate component of the estate when testing for the 36% reduced rate, to avoid discouraging gifting to charity on death. This would protect those who have already planned to make gifts under the existing rules and give more flexibility to those who want to make charitable gifts to reduce IHT on their pension assets only.
- The government should consult on options to introduce a single common statutory framework for Employment status in the UK.
- This would have a statutory underpinning similar to the Statutory Residence Test (SRT) and would provide clarity on the treatment for most arrangements while being consistent for tax and employment rights purposes.
- Once the framework is in place, the HMRC Check Employment Status for Tax (CEST) tool should also be overhauled and replaced with a tool reflecting the new test.
- Where appropriate, the government should consider whether employment tribunal decisions should apply for tax purposes, and vice versa.
- All mileage rates, including cars, motorbikes and bicycles, should be increased.
- This would reflect the current costs of running and maintaining a personal vehicle. The rates should be reviewed at least annually, in a similar way to HMRC's advisory fuel rates for company car users.
- A rate of at least 60p per mile for a car or van, regardless of business mileage, is suggested.
- Tax relief should also be available for passenger payments where the employer does not make them.
- The tax exemption for annual parties and social functions should be increased.
- The exemption should be set at a level that allows employers to organise social events without incurring a tax liability.
- The exemption has remained at £150 per head (including VAT) since April 2003. It should be increased to at least £280 per head (including VAT) to reflect higher costs and inflation.
- The limit on Trivial benefits should be increased, as it has not changed since April 2016.
- The £50 trivial benefits limit should be increased to £70. The £300 annual cap on benefits provided to directors and their households/families should increase to £425.
- Relief should also apply where an employer reimburses an employee for a purchase that would have qualified had the employer paid for it directly, including where the employee reimbursed is not the recipient of the benefit.
- The existing late filing Penalty easement for MTD should be extended for those who are joining the system for the first time in 2027-28.
- Over one million lower-income taxpayers are expected to join MTD for the first time in April 2027. An extension to the soft landing for penalties would give these newcomers time to get to grips with the complexity of MTD without worrying about penalties.
The Chartered Institute of Taxation (CIOT)
The CIOT has made a single submission recommending six targeted legislative changes to the new IHT rules for pensions. Five of these repeat points from its letter to the Financial Secretary to the Treasury of 31 July 2026. The CIOT has concerns that time is running out to fix a number of administrative hurdles which the new rules face before they take effect on 6 April 2027.
The CIOT's recommendations are:
- Where pension funds are discovered after HMRC has issued a certificate of discharge, the estate rate of tax should be paid by the pension beneficiaries and the pension administrators should notify HMRC of such payments. This would avoid having to recalculate the tax on the rest of the estate.
- Loss relief should be available for pension assets where the scheme administrator sells the assets within 12 months of death.
- The IHT instalment payment provisions should be extended to include pensions.
- The interaction between the charitable giving rules and the reduced rate of IHT should be reformed.
- Once pension wealth is included in estates, some estates will no longer satisfy the 10% rule needed to obtain the reduced rate of 36%. Conversely, percentage-based legacies may produce larger charitable gifts than intended, at the expense of residuary beneficiaries.
- The CIOT recommends a separate component for pension assets.
- The six-month payment deadline should be extended as it is unrealistic and unreasonable.
- A twelve-month payment deadline is preferred.
- Families should be helped to fund IHT liabilities in family companies.
- Agricultural Property Relief and Business Property Relief changes have brought more family companies into the scope of IHT, with assets often tied up in family companies.
- To avoid the sale of businesses to cover IHT liabilities, the undue hardship condition for a company purchase of its own shares should be removed. The current legislation only allows capital treatment on a company's Purchase of own shares used to fund IHT where the Personal Representatives (PRs) would otherwise face undue hardship.
The Institution of Chartered Accountants in England & Wales (ICAEW)
The ICAEW made a number of representations aimed at turning around the public finances, kickstarting growth, unlocking investment and empowering places, including several aimed at improving the tax regime.
The representations aimed at improving the tax regime were:
- Fix tax administration.
- Prioritise the quality of tax administration and the tax dispute resolution system.
- Require HMRC to provide an accessible, reliable and effective service to taxpayers and agents.
- Improve HMRC's governance, skills and technology.
- Fix the foundations for a successful rollout of MTD for Income Tax.
- Extend the soft landing for penalties for each population of mandated taxpayers.
- Initiate a post-implementation review of the first cohort of taxpayers to adopt MTD and delay the rollout of the £30,000 threshold until that review has concluded.
- Reform tax to promote growth and take a new approach to tax policymaking.
- Radical reform of business rates to reduce costs for businesses and encourage growth.
- Moving towards a simplified VAT system with a wider base, fewer exemptions and a lower single rate.
- Addressing 'cliff edges' in the tax system that discourage people from working more or growing their businesses.
- Clarify employment status. There is a need for clearer rules on employment status within the current tax system.
- This would assist businesses to comply with both tax and employment law.
- Rule out further increases in employment taxes during this Parliament.
- Targeted tax relief on pre-development costs to attract more infrastructure investment.
- Expand the current Advance tax certainty service to cover more projects, subject to evidence of success.
- Be cautious about using capital gains tax to raise revenue, as further changes could deter investment in businesses, particularly SMEs.
Useful guides on this topic
Finance Acts 2026-27: tax update and Rolling Tax Planner
This rolling planner tracks the key tax announcements that impact the 2026-27 tax year and beyond. This planner is updated on an ongoing basis.
Just how are our taxes raised and spent?
How does the UK raise its taxes? How does the UK spend its tax revenue? Which taxes raise the most revenue?
Legislation Day 2026 (subscribers)
'Legislation Day' (L-Day) was on 13 July 2026. The government published draft clauses for Finance Bill 2026-27, along with accompanying explanatory notes, tax information and impact notes, responses to consultations and other supporting documents. This is our detailed subscribers' guide to the announcements and publications.
External links
ATT
Budget Representation - IHT Simplification
Budget Representation - Employment Status
Budget Representation - HMRC approved mileage rates
Budget Representation - Extending tax relief for annual parties and social functions
Budget Representation - Reforming tax relief for trivial benefits
Budget Representation - Extension of MTD penalty soft landing
CIOT
ICAEW