Several tax and legal experts appearing before the House of Lords Finance Bill Sub-Committee warned peers that HMRC’s plans to criminalise ‘reckless untrue statements’ in direct tax cases are too vague, with one witness stating HMRC’s own examples had ‘just muddied the waters’.

There has been widespread concern about the move to introduce the ‘reckless’ offence since it was first trailed at Budget 2025, and the legal profession has now joined the criticism.

Witnesses from the Law Society of England and Wales, the Law Society of Scotland and law firm Reynolds Porter Chamberlain LLP told peers last week the proposed offence lacks clarity and could criminalise conduct that is not properly defined.