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(拢尘)
Corporation Tax 547
Excise -
Income Tax 2,047
VAT 1,863
Other compliance interventions 697
Total 5,154

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

HMRC鈥檚 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 鈥榗ustomer segment鈥� 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鈥檚 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 拢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鈥檚 WMBC Directorate is shown in the following table.

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

Note: Figures that could risk identifying entities have been aggregated and provided as 鈥榦ther issues鈥� within the table.