Recommendation 13

HMRC highlighted that over 70% of the wealthy population has agents, and this increases to 90% for the wealthiest individuals.21 We asked HMRC about its plans to tackle unscrupulous tax agents. HMRC told us that its focus is on the behaviours of agents in general rather than necessarily specifically those with wealthy clients and referred to ongoing work to develop a risking model to look at agents and their behaviour.22 HRMC also told us it had recently combined its agent compliance team with its specialist team who tackle promoters of avoidance to “cross-fertilise” skills between the two. It explained that the combined teams had over the past four years “brought in over £3 billion between them in relation to that work”.23 HMRC’s assessment of strategic risks does not include explicit risks of noncompliance posed by tax agents despite the amount of tax at stake. 24 17 Qq 26, 36, 50 18 Q 49 19 C&AG’s Report, paras 3.6-3.7 20 Qq 18, 48 21 Q 63 22 Q 59 23 Q 59 24 C&AG’s Report, paras 14, 2.11 11 Tax paid by billionaires