Inquiry · Opened 12 December 2025

Large business tax compliance

From: Public Accounts Committee

Open2 documents1 evidence session

What this inquiry is asking

The PAC is investigating whether HMRC's large business tax compliance programme is working effectively. It's examining why the scheme delivers strong returns (£95 revenue per £1 spent), but also why powers to punish non-compliant businesses remain unused and the overall tax gap has grown by £2 billion since 2021 despite the regime's existence.

Status / emerging findings

  • HMRC's co-operative compliance approach yielded £15.8 billion in 2024-25, more than double the £7.1 billion in 2021-22, but this may plateau as staffing costs rise
  • Special measures powers introduced in 2016 to sanction large businesses have never been deployed, despite being designed to deter aggressive tax planning
  • Corporation tax gap has risen £2 billion since 2021; tax under consideration for large businesses has nearly doubled from £42 billion to £70 billion
  • Separate issues flagged: £1.5 billion in unclaimed child trust fund accounts and unresolved loan charge cases remain outstanding

Why it matters

HMRC collects £337 billion annually from 2,000 large businesses; if compliance powers aren't working as designed, the tax system may be failing to hold the largest corporate taxpayers accountable.

Tone arc

Inquiry opened with apparent confidence in HMRC's yields, but shifted to critical questioning: why are deterrent powers dormant, and is the compliance model truly effective if the tax gap still grows?

Themes

tax-complianceregulatory-enforcementlarge-business-taxationtax-gaphmrc-powers

Key witnesses

John-Paul Marks (HMRC), Jonathan Athow (HMRC), Penny Ciniewicz (HMRC), Nicole Newbury (HMRC)

Reports & Government Responses

Witness sessions

Written evidence & correspondence

Themes & actors

Source · parliament.uk inquiry record ↗