Government proposals to create a mandatory register for any tax advisers  involved in ‘interaction with HMRC’ will harm the tax system, ICAEW said, and make the UK one of the most difficult tax environments in the world for practicing professionals.

ICAEW has called on the government to reconsider its plans, which would introduce a legal requirement for tax advisers to register with HMRC and introduce significant new penalties for advisers based on their client’s underpaid tax.

Penalties could be issued for any tax return where HMRC considers more tax is due, even if the tax adviser has not acted improperly. Draft legislation for the Finance Bill 2025/26 also proposes the introduction of a strict liability criminal offence for failure to disclose a tax avoidance scheme, and even partners is limited liability partnerships could be caught if they do not file their tax return on time.