Dan Tomlinson
MP for Chipping Barnet · Labour · United Kingdom
“I hope that once this Great British summer savings period ends on 1 September, we will review that and look at the impact. Of course, the challenge with any VAT reduction is whether it will be passed on to consumers. To be clear, I do not begrudge businesses having more margin, but the objective of the hon.”
“There are a whole range of challenges and also benefits from the protocol and the Windsor framework. I agree with the hon. Member that they do not provide constraints on the policy choice on VAT.”
“The Barnett formula is applied in the normal way to those changes, so the Northern Ireland Executive received £185 million in consequentials as a result of those decisions.”
“I understand that Members are specifically talking about Northern Ireland, but across the country as a whole—some hon. Members did mention the broader campaign around reductions in VAT across the UK—a reduction to 10% in VAT for hospitality would cost around £11 billion a year, which is equivalent to the total expenditure on the Royal Nav…”
“Right now, we are engaging in what could be seen as a similar proposal to the one put forward today. We are doing a time-limited reduction in VAT, not for one sector and one part of the country, but for particular leisure and hospitality activities and consumption across the country as a whole.”
“The fact that I am not announcing this change today does not mean that the Government do not take this issue seriously and understand the representations being made. We are also not standing aside.”
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“The challenge and trade-offs that we must grapple with in government are not grappled with by those who want to see such significant cuts to VAT, because we have to make sure we maintain revenue to fund the NHS in the hon Member’s constituency, and fund local councils to fill in the potholes and provide the social care that constituents need.”
“We do have one of the highest VAT thresholds among large economies in Europe and of course the Government keep all tax policy thresholds, rates and so on under review. I would be interested in the analysis that the hon. Member has carried out, though my understanding is that significantly increasing the threshold would not be revenue generating but would cost revenue for the Exchequer. This goes to a point that the hon. Member for Farnham and Bordon raised. He suggested that we should almost halve the rate of VAT for some businesses.”
“I am always happy to receive representations from Members on both sides of the House. I will look out for correspondence from the hon. Member in my very large weekend correspondence box, which I always enjoy on a Sunday evening.”
“The Conservatives say now that they would not have stuck with those plans, but had they done so—and they are the plans that they presented to the country before the election—the relief would have ended overnight in 2025.”
“I am aware, and we have had lots of discussions about it in this place, that that reform—the significant underlying reform to the business rates system—has happened at the same time as the revaluations since the pandemic have come into place, and at the same time as the Government have chosen to unwind, slowly and with significant transitional reliefs, the temporary pandemic support. That issue was raised by the hon. Member for Farnham and Bordon. When the Conservatives stood for re-election, the OBR forecasts did not earmark any funding whatsoever for continued support within the business rates system for our high streets.”
“We are fast running out of time, so let me turn to the topic of business rates, which Members have raised. It is worth noting that we are implementing significant reforms to the system. On the point around large online retailers, as far as I am aware, throughout the whole history of the business rates system—including the 14 years under the previous Government—the multiplier, otherwise known as the tax rate, for large online giants was exactly the same as that paid by a typical business on the high street. As part of fulfilling our manifesto commitment to reform the business rates system, we have introduced a really significant wedge into it: the multiplier for large online giants and their warehouses is now 33% higher than for a high street business.”
“I thank my hon. Friend for her question and the representation that she provides in this place for the small businesses in her constituency—it is a wonderful part of the world. If my team have not been in touch already today, I am hoping that we can find time to meet next week for a conversation. I know that this issue is one that is really important to her. York is a fantastic, vibrant and growing part of our economy. I expect that some of what is happening here is that the businesses in her constituency have seen their values increase by more than others in parts of the country that have not been doing as well. That is why the Government have provided a range of support for businesses. I look forward to talking about that with her in the coming days.”
“I am aware that pubs, and indeed all hospitality businesses, experienced challenges, particularly in 2022 when inflation surged to 11% as energy costs went up. To be clear, that was in large part a result of Putin’s illegal invasion of Ukraine and the impact it had on the global economy, but inflation did rise significantly, which impacted individuals and their bank balances. The Government understand that times are tough for businesses on the high street, in part because of that legacy. The hon. Member for Farnham and Bordon mentioned some statistics about pubs that are now out of date because of the change that was introduced last year; the 76% increase is not going to happen any more. In fact, three quarters of pubs, live music venues and other businesses affected by the changes that were announced last week—”
“Yes, and we extended the relief by a year, at a lower rate, and now, rather than ending it overnight, we have introduced significant transitional relief, so many of the businesses in the hon. Member’s constituency will see their increases, if they experience increases, being capped at 15%. Overall, across the system as a whole more than half of businesses are either seeing their bills flat-falling or staying at zero, and this tax change—this 33% wedge that has been introduced to the system—is, in effect, a transfer of almost £1 billion in business rate liabilities away from the high street and towards the largest businesses, which have properties worth £500,000 or more. This transfer will benefit 750,000 smaller properties on our high streets. Pubs have also been mentioned. We saw 7,000 pubs close over the 14 years between 2010 and 2024.”
“In the coming months, in my role as Exchequer Secretary I will of course continue to engage with businesses—small and large—on the important points that have been raised today, to see what more the Government can do to support them as they seek to grow, to support employment in their communities, and to support the life and vibrancy of our high streets and town centres.”
“I note, of course, that there is an increase for that business, as he set out. We are also publishing a high streets strategy. We will work on that in the coming months and it will be a cross-Government effort. Yes, the Treasury will be involved, but so will Departments such as the Home Office, so that we can support businesses that are struggling with shoplifting. We will also work with the Department for Business and Trade, and with the Ministry of Housing, Communities and Local Government. I hope that I have responded to a range of points that were made in the debate, and I thank Members for their contributions to it.”
“It can also mean that increases in their business rates can appear to be the result of higher takings but really just reflect underlying increases in higher costs, so they can feel like they are running to stand still. We will therefore look closely at the methodology used to value pubs, and hotels, and I hope that we can find a long-term—indeed, permanent—solution in time for the next revaluation, which will come in 2029, as planned. I will respond briefly to the point that was made about the increase from £800 to £1,600. I urge the hon. Member to check with the particular pub that he mentioned, but I assume it will be the case—each business is different, and I should not comment on individual businesses precisely—that the 15% relief will probably apply there too now, so there should not be a further £800 increase.”
“Three quarters will see their business rates fall or stay the same this year. Then, those rates will be frozen for two years. The crucial point, which relates to whether it is delayed or not, is that we are launching a review of the methodology that is used to assess pubs. I am sure that this issue will have come up in the roundtable on business rates organised by my hon. Friend the Member for York Central (Rachael Maskell) with businesses in her constituency, and in the engagement that other Members have with businesses in their constituencies. Pubs are valued in a relatively distinct way: their takings are used to assess their value, rather than their floor space. That can be quite opaque for pubs.”
“Clause 172 outlines what are not reasonable excuses for failing to comply, including insufficiency of funds, reliance on other persons and where legal advice is not full and accurate. Clause 173 contains relevant definitions of “arrangements”, “promotion” and “certified promoter”. The powers will enable HMRC to sever promoters’ access to UK services. In doing so, they will protect taxpayers and the tax system from the harm of tax avoidance. I commend the clauses to the Committee.”
“Clause 167 allows recipients to appeal a promoter action notice on the grounds that they are not providing goods or services to the promoter and that those goods and services are not being used to promote tax avoidance. Any recipient who does not comply with a promoter action notice may be subject to civil penalties under clause 168. The penalty is £1,000 per day. Where a penalty applies, under clause 169, HMRC may also publish information about the recipient that is viewable for 12 months. Under clause 170, information may be disclosed by HMRC to a regulator, a representative body or a trade body of the recipient where they have failed to comply. Clause 171 allows for the extension of time periods for complying with a promoter action notice.”
“These clauses introduce a power for HMRC to issue promoter action notices. As my hon. Friend the Economic Secretary outlined, these are another part of our toolkit in pursuing the promoters. The notices require businesses to stop providing goods or services where those services are used in the promotion of avoidance. Clause 163 allows HMRC to certify promoters of tax arrangements where they have breached a stop notice or a prohibition on promoting certain tax arrangements. Clause 164 outlines the conditions for issuing a promoter action notice. Clause 165 provides powers for preliminary notices to be issued by HMRC. Clause 166 allows HMRC to disclose information relating to the promoter identified in a promoter action notice.”
“The clause is a key one for going after promoters based offshore, to go to the points made in the debate so far. The Committee is right that it is tricky to go after those based overseas. That 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 Tax Policy Associates stated: “This is important; promoters have, for some time, been using offshore entities to make it harder for HMRC to take action against them. However 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.” That is part of what the clause is trying to do.”
“Member for Wyre Forest spoke about initial notices under clause 165. That is part of the process of making sure that we are engaging and collaborating with businesses so that we can agree the actions they may be required to take under a promotion action notice. He also raised the issue of what happens if businesses go further than HMRC’s request and end up severing all ties with promoters. 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. It will be up to them to do so. HMRC will not prescribe what more actions businesses may wish to take; what they must do will be tightly defined in the notices themselves. Question put and agreed to. Clause 163 accordingly ordered to stand part of the Bill. Clause 164 to 173 ordered to stand part of the Bill.”
“We will keep working with international partners to explore how best to co-operate with other authorities to ensure that these proposals, existing powers and any further powers that the Government may consider in the future can effectively tackle promoters based overseas. Opposition Members also raised the issue of appeals. It is important to note that promoter action notices are issued only towards the end of the line. Promoters can be issued them only when HMRC has certified that they have breached a stop notice, which is a serious thing, or the prohibition of the promotion of certain tax avoidance arrangements. Breaching either of those amounts to a criminal offence, so it is a serious step to have reached. Promoters will have the right to provide representations to HMRC as part of that process. The hon.”
“One of the big decisions that this Government have made is to increase the number of enforcement and compliance officers in HMRC—by, I believe, 5,500. Broadly, we are making that possible by reducing the number of HMRC customer services staff, because we are asking customers more generally to go online. We are targeting 90% online or digital interaction, so that we can save money for the taxpayer by having better, more streamlined interactions online, and then use some of that resource to more effectively resource our compliance unit. The matter of workload is important for me to consider closely, as the Minister with responsibility for HMRC, and the hon. Member is right to raise it.”
“One of the big challenges with these promoters is that, although HMRC often finds different routes to go after them, their non-compliance and the fact they are based overseas make effective enforcement difficult. I am aware of that, and I am sure that the hon. Gentleman and other Opposition Members were aware of it when they were in government. It is frustrating and difficult to go after promoters. This measure seeks to find a new way to restrict their ability to engage with products and services based in the UK, because it is only through those that they will be able to reach people in the UK in the promotion of the schemes. The shadow City Minister, the hon. Member for Wyre Forest, asked about HMRC workload. This is a good point, and one that I will focus on with officials and happily discuss in advance of the Budget.”
“These clauses introduce new powers for HMRC to issue anti-avoidance information notices. The measures are designed to strengthen HMRC’s ability to tackle the persistent problem of tax avoidance by promoters who exploit loopholes and hide behind complex structures. Clauses 174 and 175 define key terms such as “connected person” and list the anti-avoidance enactments that the powers set out in these clauses support. Clauses 176 to 180 empower HMRC to issue information notices to connected persons suspected of involvement, third parties holding relevant information and financial institutions to access banking data, subject to tribunal approval.”
“Clauses 175 to 185 ordered to stand part of the Bill. Clause 186 Offence of failing to comply with a notice Question proposed, That the clause stand part of the Bill.”
“Clause 182(2) sets out: “A requirement under subsection (1)(d) may not prohibit disclosure for, or in connection with, the purpose of— (a) complying with the notice, or (b) seeking legal advice.” It is the Government’s view that that provides sufficient scope for the recipient to be able to disclose information for legal advice, in line with the points that the shadow City Minister makes. I am of course happy to consider his recommendations. However, I do not want to disappoint him. I do not expect that the Government will introduce an amendment to the clause, because we think that the clause is already sufficient. Nevertheless, I will take away the points that he has made and consider them in my heart. Question put and agreed to. Clause 174 accordingly ordered to stand part of the Bill.”
“Daily penalties for ongoing non-compliance will also apply, plus penalties based on moneys received in connection with avoidance schemes. Clauses 197 to 199 set out safeguards, which include reasonable excuse provisions, and double jeopardy protection, which means that no penalty will be incurred if a person is already convicted. Clauses 200 to 202 set out that appeals are allowed against notices and penalties, except where tribunal approval was given. Clauses 203 to 205 provide clarification on various interpretations of terminologies, application of the provisions of the Taxes Management Act 1970 and repeals of existing legislation. I commend clauses 186 to 205 to the Committee.”
“These clauses cover the same topic—anti-avoidance information notices—as the previous ones. Clauses 186 to 190 set out that failing to comply or concealing information is a criminal offence, with a maximum penalty of up to two years’ imprisonment or a fine. Responsible persons—for example, directors—can be prosecuted if offences occur with their consent or neglect. Clauses 191 to 196 set out the civil penalties that apply for non-compliance. The penalty for failure to comply is up to £5,000 or £300 for financial institutions. For concealing information, the penalty is up to £20,000. For inaccurate information, it is up to £20,000 per inaccuracy, and for breaching disclosure restrictions it is up to £10,000.”
“Question put and agreed to. Clause 186 accordingly ordered to stand part of the Bill. Clauses 187 to 205 ordered to stand part of the Bill. Clause 206 Declaration in relation to privileged material Question proposed , That the clause stand part of the Bill.”
“As is the case with other items in this part of the Bill, we consulted extensively on these notices, with a 12-week consultation earlier in the year and a further eight-week consultation on the draft legislation when it was published. We received lots of responses and we made sure to listen to and reflect on the feedback. 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, which are set out more broadly in line with the code for Crown prosecutors. I hope that provides reassurance that although this does not stand part of the usual ways in which we ensure proper safeguards in our legal system, any prosecutions would of course be subject to the evidential and public interest tests.”
“Although existing legislation allows HMRC to publish the details of some legal professionals, HMRC cannot do so when the legal professional’s role is limited to activity subject to legal professional privilege. That prohibits HMRC from publishing the details of legal professionals who design schemes but do no more than that. These clauses amend the publishing legislation to allow HMRC to publish the details of legal professionals in those circumstances.”
“Clauses 206 to 212 make changes to ensure that HMRC can publish the details of legal professionals involved in designing tax avoidance schemes. A very small number of legal professionals have become involved in the promotion of tax avoidance schemes. They are sometimes involved in designing schemes, including by providing questionable legal advice to promoters of the scheme on the scheme’s efficacy. That legal advice can sometimes be used to help market the scheme to taxpayers, as it is held up as showing that the scheme works and is above board. In reality, however, these schemes rarely work and the scheme users end up footing an unexpected tax bill.”
“Again, that is out of step with HMRC’s other publishing powers, which permit information to be published for as long as appropriate. Question put and agreed to. Clause 213 accordingly ordered to stand part of the Bill. Clauses 214 to 216 ordered to stand part of the Bill. Clause 217 Construction industry scheme: amendments”
“Clauses 213 to 216 make changes to the disclosure of tax avoidance schemes—DOTAS—and the disclosure of tax avoidance schemes for VAT and other indirect taxes regimes. The clauses grant HMRC the authority to assess penalties directly, rather than requiring an application to the tax tribunal for determination. At present, HMRC must apply to the tribunal to determine penalties where failures in either regime have occurred. That is slowing down the process of assessing and issuing penalties, which are therefore not providing as much of a deterrent to promoters as they could. The mechanism for determining penalties is out of date in comparison with other HMRC powers under other regimes. Additionally, DOTAS regimes currently allow HMRC to publish only certain information for 12 months.”
“The changes will also tackle an emerging fraud model that uses construction industry scheme credits to reduce pay-as-you-earn liabilities and create repayments. These clauses protect the Exchequer from serious non-compliance, prevent large sums of money from going to organised criminal gangs and create a level playing field for those operating in the construction industry. I therefore commend them to the Committee.”
“However, subcontractors that apply for and obtain gross payment status can receive payments from their contractor’s gross; that is, with no deduction on account of tax by the contractor. Gross payment status is seen as the gold standard in the construction industry, with many large clients and contractors engaging only with subcontractors that hold it. HMRC’s impact on supply chain fraud has been limited by businesses within supply chains that hold gross payment status knowingly acting as buffers between compliant businesses and fraudulent businesses that steal workers’ deductions. The changes introduced today aim to have a lasting and positive impact on supply chain fraud. They allow HMRC to disrupt this model and will deter businesses from engaging with fraudulent businesses or turning a blind eye when there are clear signs of fraud.”
“Clauses 217 to 219 make changes to tackle fraud in the construction industry scheme and support the Government’s objective of closing the tax gap, tackling non-compliance and making the tax system fairer. The construction industry scheme is a revenue protection scheme introduced in 1971 to tackle non-compliance in the construction sector, which has a large proportion of mobile workers. The scheme collects approximately £9 billion of deductions each year. Recent reforms are helping HMRC to tackle fraud and non-compliance within the scheme. However, serious non-compliance, including sophisticated fraud by criminals, continues to develop and remains a significant risk. A core feature of the scheme is that contractors must make deductions on payments to subcontractors and pay the amount withheld to HMRC, in a similar way to an employer.”
“These changes are focused on tackling supply chain fraud, which relies on businesses entering into transactions they know are connected to fraudulent behaviour or where there is no reasonable explanation for the transaction, other than it being connected to fraud. Question put and agreed to. Clause 217 accordingly ordered to stand part of the Bill. Clauses 218 and 219 ordered to stand part of the Bill. Clause 220 Prohibition against unregistered tax advisers interacting with HMRC Question proposed, That the clause stand part of the Bill.”
“The shadow City Minister is right to raise that important point on this and other issues in this space. It is important that businesses that are acting legitimately and seeking to build the future of this country by engaging with construction contractors and subcontractors are not unduly burdened by changes we make to improve the effectiveness of this scheme and minimise fraud, which sadly persists in the construction sector. 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.”
“For organisations, it includes the name of each tax adviser’s relevant individuals, who will be required to undergo registration checks. Clause 223 defines how registration checks will also be applied to individuals and organisations. It focuses on those who play significant roles in decision making in an organisation’s tax advice operations. Clauses 224 to 226 establish registration conditions. At registration, tax advisers will be asked to confirm that they understand and will meet HMRC’s standards for agents.”
“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. As part of the registration process, HMRC will also verify that tax advisers and relevant individuals do not have any outstanding tax liabilities before permitting registration. That ensures that those who assist taxpayers with their tax affairs are themselves compliant and up to date. Clause 222 sets out the information required in an application to become registered with HMRC, including the name and address of the tax adviser.”
“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. Businesses and individuals who will be required to register come from a variety of professions, including chartered accountants, bookkeepers, payroll specialists and conveyancers who interact on behalf of taxpayers for stamp duty land tax. The requirement also applies to tax advisers based overseas who interact with HMRC on behalf of UK taxpayers. That is not the same as regulating tax advice. 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.”
“The hon. Member for North West Norfolk will be glad to know that I plan to make a lengthy speech on this group, because it is particularly important that I set out the points the Government wish to make. I 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. [Carolyn Harris in the Chair ] Clauses 220 to 229 require tax advisers who interact with HMRC on behalf of a client to register with HMRC and meet minimum standards from May 2026. They set out requirements to register, registration conditions, definitions of tax advice and how the process for approval of registration application will work.”
“The legislation allows HMRC to suspend advisers for 12 months when they have been sanctioned for anti-avoidance infractions, and it allows the suspension of advisers who have been issued with penalties under two information-gathering regimes. Following discussions with stakeholders, the Government have concluded that it is not proportionate to treat non-compliance with these regimes differently from non-compliance with other information-gathering regimes. I therefore commend clauses 220 to 229, schedule 19 and Government amendments 16 to 19, 39 and 40 to the Committee.”
“Clause 229 sets out that HMRC may, by notice, suspend the registration of a registered tax adviser if it is not satisfied that the adviser meets the registration conditions. To ensure powers and sanctions are targeted appropriately, the legislation includes robust safeguards that must be applied to any decision on whether to suspend registration, including the right to appeal to a tribunal. 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. Government amendments 16 to 19, 39 and 40 are simple amendments to correct the drafting and ensure that the legislation works as intended.”
“At registration, tax advisers will be asked to confirm they understand and will meet HMRC’s standards for agents. Currently, if HMRC concludes that an adviser has significantly breached the standards for agents, it can refuse to interact with that adviser. In line with that, as a result of these clauses, a serious breach would result in the adviser’s registration being suspended—that is not the case for a minor breach. As part of the registration process, HMRC will also verify that tax advisers and relevant individuals do not have any outstanding tax liabilities before permitting registration. Clause 227 sets out the process for approval of registration applications and how tax advisers will be notified. Clause 228 allows HMRC to request information from registered tax advisers to monitor their compliance with the requirements.”
“I respectfully disagree. The Government are not seeking to regulate tax advisers. 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 minimum standards. That is important so that those who assist taxpayers with their tax affairs are themselves compliant. Clauses 224 to 226 establish registration conditions.”
“We have come forward with a Bill that we think is proportionate and gets the balance right. I look forward to continuing to engage with the ICAEW in the months ahead.”
“I was just enjoying leafing through the Bill. Opposition Members raise a reasonable point. I want 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. We also need to ensure, as I said earlier, that we have a floor in the system, so that those who do not meet the standards—and who breach them in a serious way—are unable to remain registered, and, as we shall discuss later, are not able to continue to interact with HMRC. The Liberal Democrat spokesperson mentioned the ICAEW’s views on the topic. I have been engaging with the ICAEW, and my officials have also had meetings with it over the course of many months.”
“All I can say to the hon. Member is 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. The shadow Minister, the hon. Member for Wyre Forest, raised the point around the impact on tax advisers, and whether it would make it more expensive or burdensome for them to have to register in this way. It is worth noting that HMRC will not be charging for registration, and 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.”
“Financial services and legal and professional services are a key part of our growth strategy and our ability to increase productivity and improve living standards for people across the country.”
“The shadow Minister is right to encourage the Government, HMRC and Ministers to ensure that we get our policy right, and that we do not overreach. That is why we have engaged really carefully on this matter. We published a consultation back in October 2024, where we heard from stakeholders that there was actually strong support for some form of mandatory registration, and a view that it could enhance the security of tax adviser services and deter bad actors. We published a policy paper in July 2025, which we received 40 responses to, and we have had lots of feedback from other stakeholders as well. We will keep the policy under review. I will continue to engage with the ICAEW and other important voices and actors in the sector. We want to see a thriving and growing accountancy and tax advice market in the UK.”