What you may have missed on legislation day: HMRC’s Transformation Roadmap

24 July 2025

With public attention focused on the suite of draft provisions, explanatory notes and supporting documents published on 21 July 2025 for inclusion in the Finance Bill 2025-2026, one may be forgiven for having missed that the Government has also published a “Transformation Roadmap” for the modernisation of HMRC and the UK’s tax administration.

The Roadmap bills itself as a plan to deliver the Government’s three key priorities for HMRC: 

  • improving day-to-day performance for individuals and businesses;
  • closing the tax gap; and 
  • driving reform and modernisation of the UK’s tax and customs system. 

To achieve these aims, the Government intends to focus on strengthening HMRC’s digital offering for taxpayers and agents and moving to automation where possible, as well as heavily utilising AI technology to help simplify tax administration processes, and to help identify instances of non-compliance. 

Businesses will welcome any measures that genuinely simplify their tax affairs, and their interactions with HMRC, and such investment in HMRC and its systems is long overdue. The increased use of AI across the tax administrative process will clearly bring significant change to how tax is collected by HMRC in the coming years, and has the potential to streamline processes, but also to cause problems for taxpayers if not used correctly.

Notably, the Roadmap also includes a commitment to address what are described as “legal interpretation disputes” (where a taxpayer’s interpretation of the law is different from HMRC’s) through “clearer expectations in guidance products” and by “pursuing available options for legislative changes in those areas most prone to a disputed legal interpretation”. This is of particular interest following recent u-turns in HMRC’s guidance, for example on the salaried member rules, and it is worth stressing that HMRC’s guidance is merely one interpretation of the legislation, reliance on which should be approached with great care.

Overall, the Roadmap appears to be another step in the right direction in simplifying and modernising the tax administrative framework. Only time will tell how effective it is, but the Government’s commitment to publishing regular updates should make progress relatively easy to track.

For now, look out for further updates as we wait for further detail and see how the Roadmap is implemented in practice and what this means for clients.