Corporate report

Customer compliance: our approach to tax compliance for wealthy individuals and mid-sized businesses

Updated 24 November 2021

Compliance yield for the Wealthy and Mid-Sized Business Compliance (WMBC) Directorate in financial year 2020 to 2021

The following tables show the compliance yield generated by the Wealthy and Mid-Sized Business Compliance Directorate during 2020 to 2021. The head of duty compliance yield is reported on the same basis as the Annual Report and Accounts.

Wealthy and Mid-sized Business Compliance Directorate

Tax regime 2020-21(£m)
Corporation Tax 547
Excise -
Income Tax 2,047
VAT 1,863
Other compliance interventions 697
Total 5,154

HMRC’s approach to tax compliance for wealthy individuals and mid-sized businesses

HMRC’s Wealthy and Mid-sized Business Compliance (WMBC) Directorate aim to put compliance and customer service at the heart of everything we do by taking a ‘customer segment’ approach, focusing on customers rather than different types of tax, so we can target and coordinate our responses more effectively.

We focus on wealthy individuals, mid-sized businesses as well as public bodies and employment status and intermediaries, providing insight into the wealthy population, their tax affairs and the businesses they own or influence.

We also have a key part to play in promoting and supporting the growth that mid-sized businesses bring to the UK economy. This is part of HMRC’s wider work to promote growth and minimise cost to business while maximising compliance.

The government has provided extra investment in Summer Budget 2015 to support our work in maximising compliance from our customer groups. Our approach is to increase voluntary compliance among these groups using approaches which promote compliance and prevent non-compliance and challenge those who break the rules.

In 2020 to 2021, WMBC achieved compliance yield of £5.15 billion as shown in the table above.

Tax under consideration

Tax under consideration is an estimate of the maximum potential additional tax liability in each case before we have carried out a full investigation of the specific facts or analysis of relevant law. It is not actual tax either owed or unpaid, it is a tool to guide our enquiries to focus on the most significant risks that exist at any particular time.
In many cases, when we have looked at the full facts, it becomes clear that there is some lesser liability or even no further liability at all. Tax under consideration will naturally vary from time to time as outstanding issues are settled and new risks are identified.

The total is a snapshot of work in progress at a given point. Tax under consideration covers all taxes and duties, including Income Tax, Corporation Tax, VAT, PAYE and National lnsurance Contributions and Inheritance Tax. WMBC will now be publishing tax under consideration annually. In addition to the year this annual report relates to, we are also publishing the tax under consideration for the previous year.

A snapshot, as at 31 March 2020 and at 31 March 2021, of the tax under consideration figure for enquiries by HMRC’s WMBC Directorate is shown in the following table.

Inaccuracy category Tax under consideration 2019-20 Tax under consideration 2020-21
Accounting standards £18,963,633 £19,656,894
Amended returns £6,849,785 £1,749,331
Apprenticeship Levy £2,903,454 £3,746,108
Assessment - NICS £1,473,743 -
Avoidance £1,770,588,588 £1,064,146,564
Capital allowances £68,435,821 £59,912,320
Capital Gains £292,867,530 £752,255,590
Charities £24,658,762 £20,689,367
Claims outside returns £118,956,787 £122,310,542
Company structure £106,648,037 £296,838,520
Consideration £10,117,871 £13,110,194
Corporation Tax Capital Gains £102,981,364 £105,694,177
Covid schemes - £1,997,600
Creative industry and cultural reliefs - £773,745
Crypto assets £141,500 £427,842
Earnings £42,684,497 £34,706,203
Employment issues £616,535,882 £711,466,990
EU issues £5,014,918 £3,474,268
Expenses £252,279,894 £293,146,789
Failure to notify and late returns £25,141,821 £49,646,231
Financial £74,335,756 £76,320,358
General income £100,666,008 £139,770,790
Group litigation order £113,944 £49,427
High Income Child Benefit Tax Charge £1,102,226 £273,739
Income and expenses £111,332,340 £152,811,237
Inheritance Tax £246,542,673 £353,011,237
Input tax overclaimed £154,448,282 £262,691,172
Intangible asset regime £54,091,344 £76,176,848
International £541,582,006 £843,985,385
Investment income £84,503,314 £171,380,877
Land and property £138,202,972 £126,336,367
Loss relief £48,161,288 £53,070,720
Management expenses £1,887,183 £2,172,615
Other issues £69,114,747 £157,249,404
Output tax underdeclared £350,851,354 £386,461,134
Partial exemption £19,823,973 £77,168,069
Partnership issues £150,266,906 £126,779,167
Pension schemes £168,576,454 £175,500,125
Pre return work £1,762,328 £4,664,625
PSA/dispensation £4,855,022 £10,389,481
Research and Development claims £55,003,386 £134,993,890
Stamp Duty £55,974,120 £60,982,407
Statutory allowances/reliefs £204,105,898 £251,168,311
Trading and computations - receipts and deductions £142,076,574 £173,821,146
Transfer pricing and thin capitalisation £246,309,664 £343,842,188
Trusts £96,948,697 £48,277,171
Valuation £90,718,918 £113,147,102
VAT – other £34,490,503 £4,364,294
VAT scheme arrangements £3,013,552 £86,816
Venture capitals £427,326,962 £351,268,678
Voluntary disclosure £5,577,638 £6,935,477
Total £7,151,009,919 £8,240,899,532

Note: Figures that could risk identifying entities have been aggregated and provided as ‘other issues’ within the table.