Recommendations & Conclusions
9 items
7
Conclusion
Forty-Ninth Report - Managing tax compl…
Rejected
During the two pandemic years of 2020–21 and 2021–22, ‘compliance yield’ (the additional revenues protected as a result of HMRC’s interventions) per staff member fell from £1.3 million a year to £1.1 million (in 2021 prices).10 HMRC told us this was due to several factors, including the fact that staff …
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During the two pandemic years of 2020–21 and 2021–22, ‘compliance yield’ (the additional revenues protected as a result of HMRC’s interventions) per staff member fell from £1.3 million a year to £1.1 million (in 2021 prices).10 HMRC told us this was due to several factors, including the fact that staff redeployed away from tax compliance and onto the COVID schemes were typically more experienced.11 HMRC’s operations were also affected by external factors such as court closures and requirements on homeworking, social distancing or personal protective equipment.12
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Government response AI summary
The government disagrees with the committee's observation, stating that HMRC sets compliance yield targets to maintain a stable tax gap, deploys resources effectively, and that the tax compliance gap remained low during the pandemic years.
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HM Treasury
8
Conclusion
Forty-Ninth Report - Managing tax compl…
Rejected
HMRC did not initially recruit at scale but has more recently recruited 4,800 new compliance staff, leading to 2,500 more FTE than in 2021–22. HMRC expects staff productivity to increase over the next few years, but told us that new staff take up to four years to be fully productive. …
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HMRC did not initially recruit at scale but has more recently recruited 4,800 new compliance staff, leading to 2,500 more FTE than in 2021–22. HMRC expects staff productivity to increase over the next few years, but told us that new staff take up to four years to be fully productive. The return per staff member is therefore likely to stay lower than before the pandemic due to lack of experience among newer staff.13 Prosecutions
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Government response AI summary
The government explicitly disagrees with the committee's observation (interpreted as a recommendation), explaining that reduced yield during the pandemic was due to staff deployment to the Taxpayer Protection Taskforce. They assert that compliance performance should be viewed on a multi-year basis and that HMRC constantly …
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HM Treasury
12
Conclusion
Forty-Ninth Report - Managing tax compl…
Rejected
HMRC defines compliance yield as the additional revenue collected and protected that would have otherwise been lost to the Exchequer if not for HMRC’s interventions. It is the most direct measure of the impact of HMRC’s compliance work, and it covers both the broad effect of its measures to prevent …
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HMRC defines compliance yield as the additional revenue collected and protected that would have otherwise been lost to the Exchequer if not for HMRC’s interventions. It is the most direct measure of the impact of HMRC’s compliance work, and it covers both the broad effect of its measures to prevent non-compliance and the direct impact of its enquiries and investigations into non-compliance that has already happened.20
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Government response AI summary
The government disagrees with the recommendation, stating that HMRC sets compliance yield targets based on an agreed methodology with HM Treasury and the OBR, aimed at maintaining a stable tax gap and delivering revenues from fiscal event measures.
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HM Treasury
13
Conclusion
Forty-Ninth Report - Managing tax compl…
Rejected
In the five years before the pandemic, HMRC collected or protected an average of 5.2% of tax revenues through its compliance work. In 2020–21, total tax revenues fell as a result of the pandemic, but compliance yield fell slightly further, dropping to 5.0% of total revenues. In 2021–22, total revenues …
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In the five years before the pandemic, HMRC collected or protected an average of 5.2% of tax revenues through its compliance work. In 2020–21, total tax revenues fell as a result of the pandemic, but compliance yield fell slightly further, dropping to 5.0% of total revenues. In 2021–22, total revenues rose by 20% to record levels following the reopening of the economy and other factors such as higher inflation. However, compliance yield did not recover at the same pace, dropping to 4.2% of total revenues. This drop equates to a £9 billion reduction in compliance yield over the two years, compared with previous performance.21 HMRC told us that this partly reflected the economic impacts of the pandemic, and that there was less yield to be had. However, it also acknowledged that the reduction was affected by reductions in its own work, and a reduced ability of taxpayers to engage with its enquiries.22
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Government response AI summary
The government disagrees with the committee's observation, stating that HMRC sets compliance yield targets to maintain a stable tax gap, deploys resources effectively, and that the tax compliance gap remained low in the pandemic years in line with pre-pandemic levels.
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HM Treasury
14
Recommendation
Forty-Ninth Report - Managing tax compl…
Rejected
We asked HMRC whether, to catch up on compliance yield lost during the pandemic, it should expect to generate higher levels of yield than before the pandemic over the next few years. HMRC acknowledged that this should happen over time and suggested that no tax should go uncollected as a …
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We asked HMRC whether, to catch up on compliance yield lost during the pandemic, it should expect to generate higher levels of yield than before the pandemic over the next few years. HMRC acknowledged that this should happen over time and suggested that no tax should go uncollected as a result of the pandemic because it can go back up to 20 years with its compliance enquiries. However, it told us that other risks of non-compliance may take priority. There are also timing issues between when taxes are owed and when HMRC records compliance yield, meaning the full impact of the pandemic will not be known for several years.23 HMRC would therefore not be drawn on what levels of compliance yield it should target in the coming years, either as a percentage of total revenues or in cash terms, beyond aiming for £36 billion in the current year. It told us this was due to uncertainty in the economy and inflationary pressures.24 18 Treasury Minutes, Government responses on the Thirty Fourth to the Thirty Sixth; the Thirty Eighth; and the Fortieth to the Forty Second reports from the Committee of Public Accounts: Session 2015–16, Cm 9323, July 2016 19 https://www.gov.uk/government/publications/hmrc-datalab 20 C&AG’s Report, para 2.2–2.3 21 Qq 35, 85; C&AG’s Report, para 11–12 22 Qq 35, 45–46, 85 23 Qq 85–86, 88; C&AG’s Report, para 2.8–2.9 24 Qq 89–95 Managing tax compliance following the pandemic 11 2 Understanding how to catch up following the pandemic Supporting taxpayers who want to pay their taxes correctly
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Government response AI summary
The government explicitly rejects the recommendation to target higher compliance yield, explaining that HMRC sets targets based on an agreed methodology with the Treasury and OBR to maintain a stable tax gap. HMRC prioritizes compliance risks, ensuring identified risks can still be addressed.
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HM Treasury
23
Conclusion
Forty-Ninth Report - Managing tax compl…
Rejected
HMRC is funded to stop the tax gap from growing. The tax gap is an important measure of how much revenue may be missed—due to evasion, avoidance or non-payment —that could otherwise fund vital public services.38 32 C&AG’s Report, para 2.2, 2.14 33 Qq 57–58, 64–65; C&AG’s Report, para 2.12 …
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HMRC is funded to stop the tax gap from growing. The tax gap is an important measure of how much revenue may be missed—due to evasion, avoidance or non-payment —that could otherwise fund vital public services.38 32 C&AG’s Report, para 2.2, 2.14 33 Qq 57–58, 64–65; C&AG’s Report, para 2.12 34 Qq 56, 59, 67–70, Letter from Jim Harra, 9 February 2023 35 Letter from Jim Harra, 9 February 2023; C&AG’s Report, para 2.12 36 Qq 59–60 37 Qq 61–66; C&AG’s Report, para 2.13 38 Qq 1, 44, 90, 106; C&AG’s Report, para 2.18 Managing tax compliance following the pandemic 13
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Government response AI summary
The government disagrees with the committee's observation, asserting that HMRC's funding is sufficient to maintain compliance performance and a stable tax gap, with investments already made to tackle serious tax fraud and compliance risks.
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HM Treasury
24
Conclusion
Forty-Ninth Report - Managing tax compl…
Rejected
Due to the way it is estimated, the tax gap does not yet reflect the full impact of the pandemic and will not do so for some time. HMRC’s latest estimate is that the tax gap remained stable in 2020–21, at 5.1% of taxes theoretically owed. However, HMRC’s tax gap …
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Due to the way it is estimated, the tax gap does not yet reflect the full impact of the pandemic and will not do so for some time. HMRC’s latest estimate is that the tax gap remained stable in 2020–21, at 5.1% of taxes theoretically owed. However, HMRC’s tax gap estimates typically need to be revised over several years as it gets more data. HMRC told us that its 2020–21 estimate has a much larger range of uncertainty than normal, because of the impact the pandemic had on some of the key data sources it uses.39
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Government response AI summary
The government disagrees with the committee's observation, stating that HMRC's funding levels are adequate, with a track record of investment in compliance to generate revenue and maintain a stable tax gap, as shown in the 2023 Measuring Tax Gaps publication.
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HM Treasury
25
Recommendation
Forty-Ninth Report - Managing tax compl…
Rejected
Some measures that affect the tax gap have weakened since the start of the pandemic, indicating that the tax gap may grow in the coming years. Non-payment of taxes owed is one such component of the tax gap that HMRC expects will grow. Levels of debt and non-payment rose considerably …
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Some measures that affect the tax gap have weakened since the start of the pandemic, indicating that the tax gap may grow in the coming years. Non-payment of taxes owed is one such component of the tax gap that HMRC expects will grow. Levels of debt and non-payment rose considerably during the pandemic, and debt levels are not reducing as quickly as HMRC expected them to.40 Compliance yield, which reduces the tax gap, also saw a significant drop during the pandemic.41 HMRC’s Customer Compliance Group (CCG) produces planning estimates of the level of compliance yield it thinks it will need to achieve to stop the tax gap from growing, and the range of yield it thinks it could achieve. Its own planning estimates indicate that it is unlikely to generate enough compliance yield to stop the tax gap from growing in the next few years. The gap between the required level and HMRC’s mid-point planning estimate equates to around £17 billion in total over the three-year period. HMRC would need to achieve its upper estimate of compliance yield to stop the tax gap from growing, but in practice expects to achieve somewhere between its upper and mid-point estimates.42
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Government response AI summary
The government rejects the committee's implication, asserting its commitment to ensure HMRC has sufficient funding to maintain compliance performance and tackle the tax gap. It highlights a £79 million investment in Autumn Statement 2022 for staff to combat tax fraud and risks among wealthy taxpayers, …
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HM Treasury
26
Recommendation
Forty-Ninth Report - Managing tax compl…
Rejected
We asked whether HMRC needed more resources to catch up on the impact of the pandemic and to keep the tax gap from growing, and whether it was looking to recruit more. HMRC acknowledged that it will be more challenging to maintain the tax gap than it has been in …
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We asked whether HMRC needed more resources to catch up on the impact of the pandemic and to keep the tax gap from growing, and whether it was looking to recruit more. HMRC acknowledged that it will be more challenging to maintain the tax gap than it has been in the recent past but did not indicate what contingency plans it had if its resources were insufficient.43 HMRC told us that it will be gradually reintegrating staff from COVID-19 work to tax compliance between April and September 2023.44 It also told us that it has recruited 4,800 staff to its compliance group in the past two years. However, it takes up to four years for new staff to be fully trained and to gain enough experience to be fully effective, due to the complex nature of tax legislation and investigations which require skills ranging from technical tax knowledge to project management.45 HMRC also argued that it has up to 20 years to pursue cases of suspected non-compliance during the pandemic. However, this only applies to cases of suspected fraud. For errors the period is less, and in some cases HMRC cannot go back more than four years.46 39 Qq 82–83, 93–95 40 Qq 35–36, 41, 81, 84 41 Qq 35, 85; C&AG’s Report, para 12 42 C&AG’s Report, para 18 43 Qq 44, 85–87 44 Q 43 45 Qq 44, 80; MFP0001 46 Qq 25, 85–87 14 Managing tax compliance following the pandemic
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Government response AI summary
The government rejects the committee's suggestion regarding resource sufficiency, affirming its commitment to provide HMRC with adequate funding. It cites a £79 million investment from Autumn Statement 2022 to hire staff targeting serious tax fraud and wealthy taxpayers, emphasizing its strategic approach to deploying resources.
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HM Treasury