Recommendations & Conclusions
18 items
3
Conclusion
40th Report - Collecting the right tax …
Accepted
HMRC cannot identify how much tax is paid by UK billionaires, despite the relatively small number of individuals and significant sums of money involved. HMRC can and must do more to understand and explain the contribution that the very wealthiest in society make to tax revenue. It has access to …
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HMRC cannot identify how much tax is paid by UK billionaires, despite the relatively small number of individuals and significant sums of money involved. HMRC can and must do more to understand and explain the contribution that the very wealthiest in society make to tax revenue. It has access to a wide range of internal and external data which it uses to identify wealthy individuals, but we are disappointed that it cannot use these data to provide some transparency about the tax paid by the wealthiest. HMRC argues that income and chargeable gains determine whether you pay tax, not whether you are a billionaire. HMRC does not collect information on taxpayers’ wealth and says that it only collects the data needed to administer the tax system as required by UK tax legislation. A billionaire has wealth and assets 500 times greater than a wealthy individual who just meets HMRC’s threshold for the wealthy population and so has huge potential on their own to affect the tax gap, and how much revenue is available for public spending. In the United States, the Inland Revenue Service has worked with researchers to link its data to the Forbes 400. HMRC has not facilitated a similar analysis with the Sunday Times Rich list. recommendation Alongside its Treasury Minute response, HMRC should write to the Committee with its plans for improving its understanding of the wealth and assets held by the wealthiest individuals, including billionaires. This should include: 4 • work it can implement straightaway on comparing available data on known billionaires, such as the Sunday Times Rich List, with its own records; • the steps it will take to request more data on assets and wealth from those taxpayers it suspects have high or very high levels of wealth, taking into account that any additional administrative burdens on the very wealthiest are likely to be perfectly manageable given their resources; and • work it will undertake, and associated timeframes, to better understand the links bet
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Government response AI summary
The government states the recommendation is implemented, with the First Permanent Secretary of HMRC having written to the Committee detailing steps to improve understanding of personal wealth and connected entities. HMRC also announced plans to enhance its approach to offshore tax non-compliance.
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HM Treasury
4
Conclusion
40th Report - Collecting the right tax …
Accepted
There is much more that HMRC can do to improve its work to risk assess and target wealthy people, in particular through the use of data and technology and recruiting wealth management experts. HMRC says targeting its resources on more complex, higher-risk, higher yield cases, has resulted in higher average …
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There is much more that HMRC can do to improve its work to risk assess and target wealthy people, in particular through the use of data and technology and recruiting wealth management experts. HMRC says targeting its resources on more complex, higher-risk, higher yield cases, has resulted in higher average returns, increasing from £34,000 to £94,000 per case in the wealthy team. But the wealthy team closed 46% of its investigations with no yield at all in 2023–24. HMRC says it would like to reduce this number but explained that it does not know the facts until it opens an inquiry, when it may simply find that everything is lawful and in order. We think there is scope for HMRC to use artificial intelligence (AI) to better exploit and analyse data and, in this way, improve its risk assessment and targeting of wealthy individuals. Possible uses of AI to speed up the system include sifting large amounts of data and suggesting what information is missing from tax returns. HMRC agrees and expects new investment in AI, along with recruiting experienced tax specialists to help the wealthy team’s understanding of wealth planning, to help it to better target its compliance activity so that, when it opens a case, it has a higher likelihood of securing the yield. recommendation Alongside its Treasury Minute response HMRC should write to the Committee to explain how confirmed funding to date will feed through to better compliance performance, and what it expects to achieve from future investment. This explanation should go beyond just the impact on compliance yield and should cover the expected impact on other performance measures, such as the proportion of cases that result in a positive return. HMRC should include in that letter further details of its plans to invest in new IT, as well as plans to ensure it has the right skills to undertake the data analysis necessary to risk assess and target wealthy people. 5
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Government response AI summary
The government states the First Permanent Secretary of HMRC has written to the Committee outlining how investment plans aim to improve compliance outcomes. HMRC is currently designing how investment will be deployed and will provide more detailed plans to the Committee by Autumn 2026, building …
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HM Treasury
5
Conclusion
40th Report - Collecting the right tax …
Accepted
Too many compliance investigations last too long, with too few leading to penalties and prosecutions. HMRC has different actions it can take against taxpayers who it identifies are at risk of not paying the right tax, including penalties, civil investigations into taxpayers suspected of fraud, and criminal investigations. The average …
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Too many compliance investigations last too long, with too few leading to penalties and prosecutions. HMRC has different actions it can take against taxpayers who it identifies are at risk of not paying the right tax, including penalties, civil investigations into taxpayers suspected of fraud, and criminal investigations. The average time it took for HMRC to close an investigation increased every year over the period 2018–19 to 2022–23 and, for investigations yielding more than £100,000, the average duration in 2023–24 was 40 months. But in 2023–24, there were only 25 criminal prosecutions of wealthy individuals, and 456 penalties, down from 1,747 penalties in 2022–23. HMRC’s current ambitions to increase prosecutions and penalties are underwhelming, given that its ambition for a 20% increase in the number of people charged with tax fraud would only mean another five cases annually for the wealthy population. It is particularly disappointing that HMRC has issued no penalties to enablers of tax evasion, despite acknowledging unscrupulous advisers often play a key role in helping the wealthy evade tax. We are also unconvinced that HMRC fully utilises the deterrent effect of publicising successful prosecutions, despite it acknowledging the value of publicising high value, high-profile cases. recommendation a. HMRC should assess whether it is using its powers to tackle non-compliance by the wealthy sufficiently, in particular, whether it makes sufficient use of available sanctions. b. HMRC should investigate and report back to the Committee on why it has not been able to issue any penalties to enablers of tax evasion, and how it plans to start using them as an effective sanction and deterrent. As part of this, HMRC should consider setting an annual target for the number of penalties it issues. c. HMRC should also show more ambition for the number of prosecutions of wealthy individuals evading tax, given its current plan is to increase the number charged each year by onl
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Government response AI summary
The government has announced an ambition to increase positive charging decisions for harmful fraud by 20% to 600 per year by 2029-30, expecting a corresponding increase in criminal investigations of wealthy individuals. HMRC has already significantly increased investigations of wealthy individuals and clarifies that prosecution …
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HM Treasury
6
Conclusion
40th Report - Collecting the right tax …
Accepted
It is not sufficiently clear how much tax is paid, and how much tax is avoided by the very wealthy, which restricts HMRC’s ability to reassure the public that it administers the system fairly. Fairness is at the heart of HMRC’s charter. It is important for confidence and trust in …
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It is not sufficiently clear how much tax is paid, and how much tax is avoided by the very wealthy, which restricts HMRC’s ability to reassure the public that it administers the system fairly. Fairness is at the heart of HMRC’s charter. It is important for confidence and trust in HMRC, which has been decreasing in recent years, that the public know the wealthiest are paying their fair share. We welcome the new Permanent Secretary’s commitment to improving trust in the tax system, including examining opportunities to provide greater transparency regarding the 6 amount of tax wealthy taxpayers pay and the contributions of different segments within the wealthy population. HMRC also needs to improve its assessment of the amount of tax that the wealthy avoid paying. HMRC says that the wealthy and offshore tax gaps are particularly difficult to measure. Given these difficulties, and the deficiencies in HMRC’s information on wealth, we are concerned that HMRC is overly confident and optimistic in its estimate that the wealthy tax gap is only £1.9 billion. Its partial estimate of the offshore tax gap, of £0.3 billion, seems far too low, particularly when compared with UK residents holding £849 billion in offshore accounts in
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Government response AI summary
The government agrees and states HMRC is scoping work to better understand and more accurately capture the contribution of wealthy individuals and their controlled entities to the overall tax gap. HMRC will write to the Committee in Autumn 2026 with an update on progress in …
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HM Treasury
1
Conclusion
40th Report - Collecting the right tax …
Accepted
On the basis of a report by the Comptroller and Auditor General, we took evidence from HM Revenue and Customs (HMRC) on collecting the right tax from wealthy individuals.1
Government response AI summary
The government committed to HMRC publishing its plan in spring 2026, detailing how it will improve compliance among wealthy individuals and setting out specific timelines and outcomes for each objective.
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HM Treasury
7
Recommendation
40th Report - Collecting the right tax …
Accepted
We asked HMRC about its ambitions and priorities for ensuring that wealthy individuals pay all the taxes that they should. HMRC told us that it has significant opportunity to do more and that is working with Ministers to secure the funding and ensure that the wealthy team has the capacity …
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We asked HMRC about its ambitions and priorities for ensuring that wealthy individuals pay all the taxes that they should. HMRC told us that it has significant opportunity to do more and that is working with Ministers to secure the funding and ensure that the wealthy team has the capacity and capability it needs to undertake more activity.9 HMRC told us it has secured funding to increase the current wealthy team of around 1,000 people by an additional 400 staff. It aims to bring in at least an additional £500 million of yield over the next three or four years from more resources and activity focused on tackling wealthy offshore risks.10 5 C&AG’s Report, para 4 6 Committee of Public Accounts, Collecting the right tax from wealthy individuals written evidence 7 C&AG’s Report, paras 3.2, 3.3 8 Q 107 9 Qq 11, 67 10 Qq 11, 13, 49 9
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Government response AI summary
HMRC will set out what investments will help improve a range of compliance outcomes for the wealthy customer population by Autumn 2026, after further design work on how the investment it has received through the Spending Review will be deployed. At Spring Statement 2025, the …
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HM Treasury
8
Recommendation
40th Report - Collecting the right tax …
Accepted
HMRC told us that it wants to ensure that its wealthy team has the enablers and capabilities it needs to be more effective and productive in its work. It said that it is a constant endeavour for it to collect more tax from wealthy individuals because those who deliberately try …
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HMRC told us that it wants to ensure that its wealthy team has the enablers and capabilities it needs to be more effective and productive in its work. It said that it is a constant endeavour for it to collect more tax from wealthy individuals because those who deliberately try to evade tax will continue to do so. HMRC told us about the significant opportunities it has identified relating to data exchange, targeting and risking, collaborating globally with other tax jurisdictions, and policy changes that will help it close the tax gap.11 HMRC explained the importance of working with other international tax jurisdictions to increase the exchange of data so that there are fewer places for people to hide their assets. It told us how more data helps it to find out about big offshore balances or companies that are not reporting their income, and that it can use its investigative experts to go after this money.12
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Government response AI summary
HMRC will set out what investments will help improve a range of compliance outcomes for the wealthy customer population by Autumn 2026, after further design work on how the investment it has received through the Spending Review will be deployed. At Spring Statement 2025, the …
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HM Treasury
9
Recommendation
40th Report - Collecting the right tax …
Accepted
HMRC told us that its ultimate objective is to reduce the overall tax gap, and it hopes the increase in its compliance activity will reduce the tax gap over the next few years.13 The Office for Budget Responsibility (OBR) has forecast a reduction in the tax gap from 4.8%, at …
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HMRC told us that its ultimate objective is to reduce the overall tax gap, and it hopes the increase in its compliance activity will reduce the tax gap over the next few years.13 The Office for Budget Responsibility (OBR) has forecast a reduction in the tax gap from 4.8%, at the time it did its calculations, to 4.4% by the end of the forecast period which, if achieved, is expected to equate to an additional annual yield of £7.5 billion.14 Allowing for different levels of wealth
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Government response AI summary
HMRC will publish its plan in Spring 2026 on how it will improve compliance by the wealthy population and set out timelines and outcomes for each objective, as part of its Transformation Roadmap published in July 2025.
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HM Treasury
10
Recommendation
40th Report - Collecting the right tax …
Accepted
Around 29,000 wealthy individuals had incomes of at least £1 million in 2023–24 and were liable for around £34 billion of Income Tax in total. Within this population are taxpayers with very high incomes and wealth: around 10,000 taxpayers have annual incomes of at least £2 million, and 5,000 have …
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Around 29,000 wealthy individuals had incomes of at least £1 million in 2023–24 and were liable for around £34 billion of Income Tax in total. Within this population are taxpayers with very high incomes and wealth: around 10,000 taxpayers have annual incomes of at least £2 million, and 5,000 have assets of at least £50 million. The complexity and mobility of the very wealthiest means they carry a heightened risk, but HMRC has no particular focus on this group, and has not assessed the level of risk or the impact of its compliance activities for different income or wealth bands to understand whether it should particularly focus on the wealthiest individuals.15
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Government response AI summary
HMRC will undertake further analysis to enhance its understanding of how different levels of wealth and complexity impact risk in the wealthy population, to improve its identification and targeting of risk. Target implementation date: Autumn 2026.
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HM Treasury
11
Recommendation
40th Report - Collecting the right tax …
Accepted
We asked HMRC whether it would be useful if it segmented the population of wealthy individuals to focus on the very wealthiest taxpayers, and whether it saw different risks from these wealthiest individuals.16 HMRC observed that people’s propensity for risk will vary and that it sees a lot of risk …
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We asked HMRC whether it would be useful if it segmented the population of wealthy individuals to focus on the very wealthiest taxpayers, and whether it saw different risks from these wealthiest individuals.16 HMRC observed that people’s propensity for risk will vary and that it sees a lot of risk at lower wealth bands, not just from billionaires. HMRC stressed the importance 11 Q 11 12 Q 13 13 Q 77 14 Q 77 15 C&AG’s Report, paras 1, 10, 1.17 16 Qq 26, 50 10 of having a risk model that considers other factors besides pure wealth, such as complexity and opportunity for non-compliance. It said it otherwise might miss those people who are causing more harm to the tax system than just the very wealthy. It compared a very wealthy individual, earning a lot of income through Pay As You Earn and therefore highly visible to HMRC, to another individual with much lower wealth who places properties in very complex offshore trusts and structures which may be indicative of non-compliant behaviour.17 Nevertheless, HMRC acknowledged that it needs to keep its definition of the wealthy population under review and accepted that the case for better segmentation was well made.18
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Government response AI summary
HMRC will undertake further analysis to enhance its understanding of how different levels of wealth and complexity impact risk in the wealthy population, to improve its identification and targeting of risk. Target implementation date: Autumn 2026.
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HM Treasury
12
Conclusion
40th Report - Collecting the right tax …
Accepted
Customer Compliance Managers (CCMs) within the wealthy team provide a single point of contact for the taxpayer and their agent and develop an in-depth understanding of a wealthy individual’s financial affairs to identify risks and support the taxpayer to be compliant. The wealthy team has around 100 CCMs in post …
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Customer Compliance Managers (CCMs) within the wealthy team provide a single point of contact for the taxpayer and their agent and develop an in-depth understanding of a wealthy individual’s financial affairs to identify risks and support the taxpayer to be compliant. The wealthy team has around 100 CCMs in post and, as at February 2025, had assigned a CCM to around 15,000 taxpayers it perceived to have the highest levels of complexity or opportunity for non-compliance (2% of wealthy individuals).19 HMRC told us that it deploys its CCMs according to those who pose the greatest risk and says they typically end up working on cases relating to individuals with wealth above £10 million. But HMRC acknowledged it may need to make changes to its risk model as part of improving its data and risking.20
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Government response AI summary
HMRC commits to ensuring all identified billionaires with a UK tax footprint have an allocated Customer Compliance Manager (CCM), with new allocations by summer 2026, and will provide assurance of completion by autumn 2026.
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HM Treasury
14
Recommendation
40th Report - Collecting the right tax …
Accepted
HMRC has an ambition to collect more information from wealthy individuals with more complex affairs, in line with international best practice. However, HMRC has set no firm plans or timescales.25 We asked HMRC about its progress in collecting more information from wealthy individuals. HMRC told us that it is for …
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HMRC has an ambition to collect more information from wealthy individuals with more complex affairs, in line with international best practice. However, HMRC has set no firm plans or timescales.25 We asked HMRC about its progress in collecting more information from wealthy individuals. HMRC told us that it is for Ministers to make decisions about requesting more information and instead highlighted the value of international agreements in improving its access to data, as well as the future improvements it expects via crypto asset reporting and the register of overseas entities.26
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Government response AI summary
HMRC will request more data on assets and wealth from those taxpayers it suspects have high or very high levels of wealth and provide a further update in Autumn 2026 on any progress made on acquiring additional data sets. HMRC will set out its progress …
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HM Treasury
15
Recommendation
40th Report - Collecting the right tax …
Accepted
HMRC could not tell us how many billionaires pay tax in the United Kingdom and explained that income and chargeable gains determine whether someone pays tax, not whether they are a billionaire. UK tax legislation does not require taxpayers to report data on their wealth, only on income and taxable …
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HMRC could not tell us how many billionaires pay tax in the United Kingdom and explained that income and chargeable gains determine whether someone pays tax, not whether they are a billionaire. UK tax legislation does not require taxpayers to report data on their wealth, only on income and taxable events. HMRC said it therefore does not hold a list of billionaires, or have a legal mechanism for collecting information on taxpayers’ wealth.27 HMRC explained that, before this year when the non-dom regime was removed, a large number of non-domicile billionaires may have been resident in the UK with no taxation payable.28 It expects the removal of the non-dom regime, and the new requirement for these individuals to report their foreign income and gains, will enhance its information on and understanding of the some of the wealthiest individuals.29
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Government response AI summary
HMRC will continue to enhance its understanding of billionaires with a UK tax footprint and provide assurance that all billionaires with a UK tax footprint in the wealthy population have an allocated Customer Compliance Manager (CCM). CCMs are senior tax professionals who provide extra scrutiny …
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HM Treasury
16
Recommendation
40th Report - Collecting the right tax …
Accepted
The Sunday Times Rich List 2025 listed 156 billionaires, compared with 165 last year. We asked HMRC if it has ever tried to link the Sunday Times Rich List with its own records to estimate how many billionaires on the list are tax resident in the UK. HMRC told us …
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The Sunday Times Rich List 2025 listed 156 billionaires, compared with 165 last year. We asked HMRC if it has ever tried to link the Sunday Times Rich List with its own records to estimate how many billionaires on the list are tax resident in the UK. HMRC told us that it has access to a huge range of internal and external data which it uses to identify wealthy individuals, cross-check across data sources, and target its compliance work as effectively as possible but it would not be drawn on the use of specific data.30 We understand that in the United States, the Inland Revenue Service has worked with researchers to link its data to the Forbes 400 list, their equivalent of the Sunday Times Rich List. We asked HMRC if it would allow academics to do something similar with its data. HMRC agreed 25 C&AG’s Report, para 2.14 26 Qq 120-122 27 Qq 21-22, 25-26, 28-30 28 Q 35 29 Q 120 30 Qq 31-33 12 that, in theory, it would be possible for academics to use its Datalab to securely access its data for research purposes and use other information to do analysis.31
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Government response AI summary
HMRC will continue to enhance its understanding of billionaires with a UK tax footprint and provide assurance that all billionaires with a UK tax footprint in the wealthy population have an allocated Customer Compliance Manager (CCM). CCMs are senior tax professionals who provide extra scrutiny …
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HM Treasury
17
Recommendation
40th Report - Collecting the right tax …
Accepted
The NAO’s report illustrates the vast difference in levels of wealth in HMRC’s wealthy customer group. For example, a billionaire could have 100 times more wealth than someone who fits the descriptor of a “high net worth individual”, and 500 times more wealth than someone who just meets HMRC’s definition …
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The NAO’s report illustrates the vast difference in levels of wealth in HMRC’s wealthy customer group. For example, a billionaire could have 100 times more wealth than someone who fits the descriptor of a “high net worth individual”, and 500 times more wealth than someone who just meets HMRC’s definition of a wealthy individual. In 2023, HMRC secured £652 million in unpaid tax, interest and penalties from one case alone, involving a billionaire who failed to declare offshore trusts.32 HMRC told us that it wants to improve trust in the UK tax system and sees transparency about the amount of tax that wealthy taxpayers pay as one way for it to achieve this aim. It committed to look at opportunities to do more, including providing reassurance that it sufficiently understands the billionaires within its wealthy population.33 31 Q 34 32 C&AG’s Report, Figure 5, para 3.16 33 Q 38 13 2 Improving compliance and enforcement activity Targeting interventions
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Government response AI summary
HMRC will undertake further analysis to enhance its understanding of how different levels of wealth and complexity impact risk in the wealthy population, with target implementation in Autumn 2026.
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HM Treasury
20
Recommendation
40th Report - Collecting the right tax …
Accepted
HMRC told us that the investment it secured as part of its recent funding settlement will help improve its data and understanding of the risks and better target its compliance activity so that, when it opens a case, it has 34 Q 87 35 C&AG’s Report, paras 3.10, 3.15-3.16 36 …
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HMRC told us that the investment it secured as part of its recent funding settlement will help improve its data and understanding of the risks and better target its compliance activity so that, when it opens a case, it has 34 Q 87 35 C&AG’s Report, paras 3.10, 3.15-3.16 36 Qq 93, 104 14 a higher likelihood of securing the yield.37 It plans to bring in more wealth management experts to help the wealthy team’s understanding of wealth planning. It said it will also invest in its case management system and digitise the Inheritance Tax regime, which will help case workers to access data in a more timely and effective way. HMRC said it also plans to invest in artificial intelligence (AI), which it already uses in some way in the form of predictive analytics and machine learning. It said that AI presents a significant opportunity to improve productivity, through improved targeting and risking and optimising digital capabilities, which HMRC would expect to realise.38 Compliance investigations
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Government response AI summary
HMRC will set out what investments will help improve a range of compliance outcomes for the wealthy customer population by Autumn 2026, after further design work on how the investment it has received through the Spending Review will be deployed. At Spring Statement 2025, the …
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HM Treasury
23
Recommendation
40th Report - Collecting the right tax …
Accepted
HMRC has issued fewer penalties to wealthy taxpayers in recent years, and criminal prosecutions of wealthy individuals have also declined. In 2023–24, HMRC issued 456 penalties to wealthy individuals, totalling 37 Qq 20, 87-88, 90 38 Q 105 39 C&AG’s Report, para 3.18 40 C&AG’s Report, paras 17, 3.20 41 …
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HMRC has issued fewer penalties to wealthy taxpayers in recent years, and criminal prosecutions of wealthy individuals have also declined. In 2023–24, HMRC issued 456 penalties to wealthy individuals, totalling 37 Qq 20, 87-88, 90 38 Q 105 39 C&AG’s Report, para 3.18 40 C&AG’s Report, paras 17, 3.20 41 Q 96-97 42 Q 98-100 43 Q 90 15 £5.8 million. This is down from 1,747 penalties totalling £20.5 million in 2022–23, and 2,153 penalties totalling £16.2 million in 2018–19. HMRC explained that the number and value of penalties will vary depending on its caseload. For example, it charges automatic penalties for late filing, but other sorts of mistakes may not result in penalty charges. The number of wealthy individuals prosecuted following HMRC’s criminal investigations reduced significantly from 30 in 2019–20 to five in 2021–22 but has since increased to 25 in 2023–24. HMRC said it is expecting a 20% increase by 2029–30 in decisions to charge taxpayers with a criminal offence.44 In the wealthy individuals customer group, we presume this translates into five more taxpayers charged in 2029–30 than currently.
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Government response AI summary
HMRC will assess its use of powers to tackle non-compliance by the wealthy, in particular whether it makes sufficient use of available sanctions, and report back once the assessment has been completed. Target implementation date is Autumn 2026.
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HM Treasury
24
Conclusion
40th Report - Collecting the right tax …
Accepted
HMRC reserves criminal investigations for where it needs to send a strong deterrent message or where only a criminal sanction is appropriate.45 HMRC told us that deterrence works primarily through media and social media so focusing on the most severe cases, which will attract the highest penalties, is likely to …
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HMRC reserves criminal investigations for where it needs to send a strong deterrent message or where only a criminal sanction is appropriate.45 HMRC told us that deterrence works primarily through media and social media so focusing on the most severe cases, which will attract the highest penalties, is likely to be the best deterrent. It said that it has looked at whether it can quantify the deterrent effect, but it cannot put a monetary value on the impact of its criminal investigations. It did though stress the importance of the deterrent effect of taking cases to court. We raised concerns that, in some instances, HMRC is not using its existing powers to tackle non-compliance. HMRC said that it uses the powers it thinks are most effective to tackle the problems it faces.46 HMRC subsequently provided information on the total number and value of penalties issued by HMRC in relation to offshore tax evasion or non-compliance. While it acknowledged the vital importance of its use of powers for their deterrent effect, we noted that HMRC has issued no penalties to enablers of tax evasion, despite the role unscrupulous advisers often play in helping the wealthy evade tax.47 Boosting public trust and confidence through transparency
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Government response AI summary
The government agrees and states it will increase positive charging decisions for harmful fraud by 20% to 600 per year by 2029-30, with investigations including fraud facilitated by large corporations and individuals enabling offshore tax evasion, confirming the recommendation is implemented.
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HM Treasury