Professional bodies make Budget representations

In September, HM Treasury invited representations from stakeholders ahead of the 2025 Autumn Budget. We take a look at the representations made by some of the professional bodies.

Row of pound coins

HM Treasury’s portal for Budget representations closed on 15 October 2025. Comments on existing government policy were invited, along with suggestions for new policy ideas to be considered for the upcoming Budget.

Several professional bodies in the tax and accounting sector made representations and published them publicly. Below is a summary of some of the representations made.

Association of Taxation Technicians (ATT)

The ATT has published six submissions that it made. These primarily focus on employment taxes. The ATT suggests:

  • Increasing the tax exemption for Annual parties and social functions to at least £200 per head, including VAT.
    • The value of the exemption should then be reviewed regularly, with the intention of it being increased at least every five years. The current £150 per head (including VAT) exemption has been at that level since April 2003.
  • Increasing the fixed rate Working from home allowance by at least 2% for employees, with a similar increase for the Self-employed using simplified expenses.
    • This would bring rates to £6.25 per week (£27.08 per month). Rates should then be reviewed and updated annually.
  • Amending the rules for Trivial benefits to allow relief where an employer reimburses an employee for a purchase which would have qualified as a trivial benefit had the employer paid for it directly.
    • The £50 limit on trivial benefits should also be increased.
  • Increasing the Approved Mileage Allowance Payment (AMAP) rates to better reflect the current costs of running and maintaining a personal vehicle.
    • Rates should then be reviewed and updated annually.
    • Simplification could also be achieved by introducing a single rate, rather than the current two-tier approach for cars based on the total mileage in the tax year.
  • Simplifying Inheritance Tax (IHT) by:
    • Making the proposed £1 million allowance for 100% Agricultural Property Relief (APR) and Business Property Relief (BPR) from April 2026 transferable between spouses, including an uplift for individuals whose spouse died before 6 April 2026.
    • Merging the Residence Nil Rate Band and Nil Rate Band (NRB) into a single NRB.
  • Simplifying Income Tax and Self Assessment by:
    • Providing an enduring ‘opt-in’ to Self-Assessment for those who prefer to file tax returns, despite not being obliged to do so.
    • Making tax compliance easier for those who do need to be in Self Assessment, but have tax to pay. This includes:
      • Improving clarity over Simple Assessment responsibilities.
      • Allowing access to view and verify bank interest records held by HMRC.
      • Enabling the operation of PAYE on state pension payments.  
    • Aligning the Income Tax treatment of assets jointly owned by spouses/civil partners who are living together with that applying to other joint owners.
    • Allowing carry-back of Gift Aid donations to the previous tax year via an amendment to that year’s tax return.

Chartered Institute of Taxation (CIOT)

Three Budget representations have been published by the CIOT. It recommends:

  • Reintroducing Certificates of Tax Deposit (CTDs), allowing taxpayers to deposit money with HMRC and use it later to pay certain tax liabilities.
    • This facility was particularly useful to taxpayers in dispute with HMRC, where the amount of tax ultimately due was unknown. CTDs could be purchased to stop late payment interest accruing while an investigation was ongoing, without the taxpayer appearing to concede their case.
  • Consulting on the rate and approach to repayment interest on overpaid tax, as there is currently an imbalance in repayment and late payment interest rates, with taxpayers who owe money to HMRC being charged a higher rate.
    • Repayment interest should provide adequate recompense for the loss of the use of the monies by the business or individual concerned, and an adequate incentive for HMRC to process repayments in a timely fashion.
    • For VAT, the concept of ‘commercial restitution’ when levying interest on underpaid VAT should be reintroduced to prevent interest from being charged in circumstances where there is no loss of tax to the Exchequer.
  • Addressing tax barriers to housing supply, to assist in delivering the Government’s target of building 1.5 million new homes by the end of this parliament.
    • This is a detailed submission that comments on the operation of Stamp Duty Land Tax (SDLT) reliefs, the Corporate Interest Restriction (CIR), Residential Property Developer Tax (RPDT), VAT, and the Annual Tax on Enveloped Dwellings (ATED).

Low Incomes Tax Reform Group (LITRG)

LITRG highlights one submission that it made. It, like the ATT, suggests operating PAYE on the state pension.

  • The rationale for this is that an increasing number of state pensioners are liable to pay tax on their state pension due to the frozen personal allowance and increasing levels of pension income due to inflationary uplifts.
  • Rather than relying on Self Assessment, simple assessment, or other PAYE income sources to indirectly collect the tax, LITRG says that operating PAYE on state pension payments would promote simplicity, clarity, and ease administrative burdens.

Useful guides on this topic

Finance Acts 2025-26: tax update and Rolling Tax Planner
This rolling planner tracks the key tax announcements that impact the 2025-26 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?

What might be announced in Autumn Budget 2025?
With the Chancellor's 2025 Autumn Budget set for 26 November, and an increasingly challenging economic outlook, we consider what tax changes might be announced when Rachel Reeves stands at the Dispatch Box next month.

External links

ATT

CIOT

LITRG