The draft Finance Bill 2026-27 landed on 13 July 2026. The tax world calls it L-Day. It covers HMRC’s information powers, a new duty to correct errors, cryptoassets, pensions and Pillar Two. The technical consultation runs eight weeks and closes on 7 September 2026.
What did the government publish on L-Day?
Draft clauses, notes, policy papers and, in several cases, summaries of earlier responses. The point of L-Day is to expose the drafting before a bill reaches Parliament.
The government trailed most measures at Autumn Budget 2025 or in Tax Update 2026. Little of the policy is new. The wording is.
That distinction shapes how firms should respond. The consultation is technical. Arguments about whether a policy is right fall outside it. Arguments about whether the clause does what it claims are exactly in scope.
How are HMRC’s information powers changing?
This is the measure with the widest reach into ordinary practice. It reforms Schedule 36 of the Finance Act 2008 and section 126 of the Finance Act 2021. It also updates the computer records definitions in section 114 of the 2008 Act. It takes effect on Royal Assent, not April.
Three changes stand out.
Right now HMRC cannot issue an information notice about a dead person’s tax more than four years after the death. That limit goes, subject to tribunal approval for most notices.
The Financial Institution Notice widens. It will reach firms providing crypto services. It will also reach payment firms that handle payments linked to them.
Identification notices become easier to issue. Any HMRC officer may issue one, though an authorised officer still approves it.
Private client and probate teams should read the deceased-person change closely. It reopens a window that practitioners have treated as closed.
What is the new duty to correct errors?
A legal duty on taxpayers to put things right once they spot an error in a return or other paper. At present the position rests largely on penalty rules and disclosure practice.
HMRC also gains a customer correction notice. It can issue one where it has reason to believe a document contains an error.
Advisers should watch how the drafting defines awareness. That single word decides when the duty bites. It also decides what a firm must do on spotting something in a file.
The information and inspection powers reform reaches ordinary practice hardest. It widens what HMRC can demand, and from whom. Firms with a tax practice have until 7 September to comment on the drafting. The powers take effect on Royal Assent, not at the start of a tax year.
Which Finance Bill 2026-27 measures touch pensions and property?
Two, and both connect to work already under way elsewhere.
The Bill will permit authorised member surplus payments from defined benefit schemes. That is the tax counterpart to the DWP’s draft surplus regulations. It lets a scheme pay surplus to members as a lump sum rather than as pension.
Stamp duty land tax gains a relief for transfers into Local Government Pension Scheme pooled investment vehicles. It is time-limited and narrow, but it removes a real friction in LGPS pooling.
What else is in the package?
Cryptoassets take up a large share. Crypto loans and decentralised finance liquidity pools would get no gain, no loss treatment for capital gains tax. That defers the charge until an economic disposal. Eligible stablecoins would count more like money. Qualifying disposals fall outside CGT, and interest-like returns become savings income. Both start from 6 April 2027 if enacted.
Pillar Two gets its side-by-side implementation package. A securities transfer tax would replace stamp duty reserve tax. It would also replace stamp duty on transfers of UK shares. The cultural gift scheme loses its restriction on jointly owned objects from 6 April 2027.
One small clause is worth flagging. Rewards under the Strengthened Reward Scheme lose income tax at source, at the additional rate of 45%. That starts on Royal Assent.
When does the consultation close?
7 September 2026 for the main technical consultation on the draft clauses. Two separate consultations run longer. One covers aligning time limits for recovering National Insurance contributions with income tax. The other covers land remediation relief.
The Chancellor decides the final contents. Drafting can still move before the Bill reaches Parliament. Four weeks are left. Anyone with clients holding crypto, running DB schemes or trading across borders should read the clauses.
The Legal Brief covered the pensions regulations these tax measures accompany in its report on DB surplus release. It reported earlier HMRC adviser reform in its roundup on tax adviser registration.
GOV.UK hosts the full Finance Bill 2026-27 draft legislation collection. It also hosts the policy paper on information powers. ICAEW has published a measure-by-measure summary.