Recommendation 22

In 2023–24 there were 344 criminal prosecutions, compared with 691 in 2019–20, before the pandemic.64 HMRC said it is very successful in its criminal investigations and has a high conviction rate in its prosecutions, but that it tends to reserve their use for the most serious and higher- value cases 65 We asked HMRC whether failing to prosecute some criminal behaviour reduces the deterrent effect of HMRC’s criminal investigations and leads to a culture of non-compliance.66 HMRC accepted there was a risk that the deterrent effect could reduce.67 It said it was reviewing the academic research on this topic but said there was currently limited evidence about the deterrent effect of criminal investigation and prosecution, but that it could still impose significant sanctions using civil processes.68 63 Q 23 64 Report on 2023–24 Accounts, para 1.22 65 Qq 30, 39-40 66 Q 31 67 Q 31 68 Q 31 15