hmrc ccg – customer compliance group

Tag Archive for: hmrc ccg

Is HMRC’s Worldwide Disclosure Facility working?

See Amit’s latest article, Is HMRC’s Worldwide Disclosure Facility working? Published on 14th August 2026 by the ACCA in their Accounting and Business Magazine.

 

Is the Worldwide Disclosure Facility working?

Ten years on, the WDF is not bringing in the anticipated revenue

 

Amit Puri, the Managing Director of Pure Tax Investigations examines the Worldwide Disclosure Facility ten years on, for the ACCA. He said the WDF is not bringing in the anticipated revenue.

The Worldwide Disclosure Facility initiative provides individuals who have earned income or achieved gains overseas with a streamlined opportunity to bring their UK tax affairs up to date by making a voluntary disclosure through an HMRC portal. Provided the disclosures made online are full and complete, there is no need to engage further with HMRC.

But, despite a recently growing number of disclosures, and ongoing  ‘nudging’ on the part of HMRC, the trend of total annual tax receipts has been down. Amit said there was ‘more to be done’ but HMRC has secured just under £920m from WDF to date, including taxes, statutory late payment interest and penalties. The average tax secured per disclosure figure has not increased over time

The Worldwide Disclosure Facility is an example of where HMRC’s one-to-many / nudge-letters approach has been deployed, which is not as resource intensive as one-to-one enquiries.

Nudge Letters performance

There is a correlation between the number of one-to-many letters sent out by HMRC and the number of WDF disclosures received (see graphic). However, with fewer than 2,000 informal letters being sent out a month, it is low in comparison to the millions in lines of banking accounts data HMRC receives every year.

As an example, the total number of WDF disclosures received in 2018 and 2019 was 16,589, but the number of offshore accounts reported to HMRC in, say, 2017 or 2018 was around three or four million. The data exponentially eclipsed the number of disclosures made and the number of nudge letters HMRC sent out.

Surprisingly, the average tax secured per disclosure figure has not increased over time. This is despite HMRC extending the 12-year tax-assessing rule for offshore matters and offshore transfers. One would expect there to be more tax years included in WDF disclosures.

Annual tax revenues from WDF disclosures have not increased, which seems to correlate with the low numbers of nudge letters sent out. It is unclear whether this is because HMRC is unambitious, incapable of doing more or just drowning under all the banking data.

Some suggest that HMRC has ramped up the number of regular one-to-one enquiries carried out using the bulk offshore financial accounts data, but this does not appear to be the case. It seems apparent that the number of WDF disclosures being made remains directly influenced by the number of nudge letters sent by HMRC.

Who is the Worldwide Disclosure Facility for?

This is a targeted, streamlined disclosure facility for people, whether they are living in or outside of the UK, with foreign income or foreign gains, which should have been declared in their personal tax returns but was not. To be clear, an offshore issue (matter or transfer) includes underpaid or omitted tax relating to:

  • income arising from a source outside the UK
  • assets situated or held outside the UK
  • activities carried on wholly or mainly outside the UK
  • anything having effect as if it were income, assets or activities of the kind described

An international financial accounts information exchange agreement means that over 100 jurisdictions share rich financial accounts / banking data with one another, annually and automatically, without the need to make case specific requests.

Importantly, the Worldwide Disclosure Facility offers no ‘carrots’ or inducements like fixed low penalties and immunity from a criminal tax investigation, in the way that older offshore tax disclosure facilities did.

The WDF is a streamlined process through which offshore matters can be disclosed in a uniform way by those that are experienced in preparing and submitting them. The

  • taxes
  • interest
  • penalties

that are payable, after factoring in all tax reliefs, exemptions, claims, elections and allowances, should be paid simultaneously so that cases are resolved more quickly by HMRC.

Practitioners’ takeaways

In recent months, readers may have noticed that most of HMRC’s Worldwide Disclosure Facility offshore tax related nudge letters and enquiry correspondence has been coming out of its brand new front-line directorate: Volume Compliance and Support Operations (VCSO). There is more about VCSO on our website.

Those who wait for HMRC to contact them lose the ability to make a wholly voluntary disclosure and are therefore unable to secure the minimum penalties. It is still a good time to review a client’s overseas activities, accounts, wealth etc, and ensure that UK taxes on investment income and gains are correctly calculated and disclosed.

We secure the best possible outcome for clients, based on robust knowledge about tax assessment time limits, the various offshore penalty regimes that apply and double-taxation relief quirks.

/by

HMRC’s Let Property Campaign Nears £550m

See Amit’s latest article, HMRC’s Let Property Campaign nears £550m, was published on 7th July 2026 by AccountingWEB.co.uk.

HMRC’s Let Property Campaign Nears £550m

HMRC’s let property campaign has secured close to £550m from landlords. Amit Puri explains what the latest figures reveal about rental disclosure trends, penalties and related HMRC compliance activity.

HMRC’s Let Property Campaign has been running for some thirteen years now, has seen some 100,000 disclosures made to date, and has no closure date.

Whilst nearly 100,000 have disclosed so far, over 15 years ago, HMRC had estimated some 1.5 million landlords had underpaid taxes… and that unpaid taxes for just 2009 & 2010 were c.£500 million!

LPC disclosures and compliance activities

Whilst nearly 100,000 have disclosed so far, over 15 years ago, HMRC had estimated some 1.5 million landlords had underpaid taxes… and that unpaid taxes for just 2009 & 2010 were c.£500 million!

Interestingly, the penalty rates being achieved seem much higher when HMRC carried out compliance checks and enquiries than waiting for Let Property Campaign disclosures over the same period; more than double! This should not come as a surprise though as HMRC had presumably ‘prompted’ the Let Property Campaign disclosures that came thereafter. Conversely, it is expected that most of the Let Property Campaign disclosures made were wholly voluntary, therefore ‘unprompted’ in nature.

The most interesting point to note here was that the total revenues secured, that’s tax, interest and penalties, were a lot higher as a result of HMRC carrying out one-to-one enquiries (or compliance checks if you prefer); more than double in 2024/25!

As advocates for HMRC becoming better resourced and then being able to increase the deterrence effect of the rules and powers available to them through more compliance activities, this was useful to notice. While penalties charged were undoubtedly higher in non-rental disclosure cases, so was the tax take in recent years, which appears to be the continuing trend.

In the past, we had specifically asked HMRC how many of LPC disclosures were based on ‘deliberate inaccuracies’ in tax returns or ‘deliberate failures to notify offences’. HMRC confirmed then that only about 0.5% (285 out of the 58,574 Let Property Campaign disclosures made by that time) were as such – at the most serious end of the behavioural/actions spectrum.

It follows that the number of clients recorded on HMRC’s publishing details of deliberate defaulters (PDDD) list has been very small too. One of the key criteria for being named and shamed publicly every quarter is that the underlying behaviour leading to the penalty being chargeable must be ‘deliberate’ as opposed to ‘careless’ or ‘non-deliberate’.

Readers will no doubt be aware that the Let Property Campaign remains open for their clients to utilise, and that there is no official closure date. The open-ended nature of the campaign means that it is still a good time to review a client’s activities and ensure taxes on rental profits are correctly calculated, disclosed and paid etc.

Taxes on gains on any disposals of rental properties should also be considered and declared where appropriate. Failure to do so exposes individuals to HMRC’s compliance activities, which bring with them an enquiry framework (not a lenient disclosure facility) and obviously larger penalties…

The Let Property Campaign provides a relatively smooth process for professional, amateur and novice/first-time landlords who owe taxes through having let out residential properties in the UK and abroad. It presents the best opportunity to bring their UK tax affairs up to date in a simple way, especially where they have not deliberately or dishonestly caused tax irregularities.

We would encourage seeking out specialist tax disclosure advice where there is a lack of experience in making them and handling corresponding enquiries, to secure the very best possible outcomes for clients, based on robust knowledge about strict tax assessment rules and time-limits as well as the various penalty regimes that can apply.

Practitioners’ takeaways

In recent months, readers may have noticed that most of HMRC’s Let Property Campaign rental disclosure nudge letters and enquiry correspondence has been coming out of its brand new front-line directorate: Volume Compliance and Support Operations (VCSO). There is more about VCSO on our website.

/by

HMRC’s Customer Compliance Group Explained

Amit’s latest ‘in-brief’ article, HMRC’s Customer Compliance Group Explained was published online (4 March 2026) and in print (6 March 2026) print issue of the Tax Journal.

What is HMRC’s Customer Compliance Group (HMRC CCG)?

The Customer Compliance Group was established in the second half of 2016, after a major restructure to the previously known Enforcement and Compliance Group. As at September 2025, its total staff figure for 2024/25 was 28,074 full-time equivalents (FTEs), almost half of HMRC’s entire headcount.

Prominent directorates within HMRC CCG are as follows:

  • Individuals and Small Business Compliance and Wealthy and Mid-sized Business Compliance
    • These two directorates make up the vast majority of HMRC CCG, with around 12,400 staff combined – nearly half of all CCG staff – and therefore represent the core of HMRC’s investigative and compliance resource. In practice, most enquiry letters will come from one of these two directorates.
  • Large Business: The LB directorate employs around 2,500 staff to manage around 2,000 of the UK’s largest businesses, measured by turnover.
  • Risk & Intelligence Service: RIS, with around 3,300 staff, seeks out intelligence from across the UK and offshore jurisdictions, analyses that intelligence, and assesses the tax risks it presents to the UK Exchequer. RIS has personnel in many countries, sharing intelligence and operational practices with overseas tax authorities.
  • Counter Avoidance: The CA directorate uses a range of strategies and evolving legal powers to tackle marketed tax avoidance schemes and arrangements. It focuses on disrupting promoters but also supports users exiting avoidance schemes.
  • Fraud Investigation Service: Despite employing around 4,900 staff, FIS manages the most in-depth and intrusive investigations, both civil and criminal in nature. These are not routine compliance cases, but cases involving serious tax fraud, dishonesty or criminal conduct.
    • FIS was formed in 2015 from the merger of Specialist Investigations and Criminal Investigations. Today, it is organised into the Prosecutions Unit, the UK Tax Matters Unit and the Offshore, Corporate and Wealthy Unit.

Practitioners’ takeaways

Most compliance checks will continue to be initiated by ISBC and WMBC. The smallest taxpayers fall within ISBC’s remit, which remains HMRC’s largest single directorate. It is HMRC’s duty to create a deterrence effect, otherwise scrutiny may appear to fall disproportionately on larger and more complex businesses.

While FIS attracts significant attention, only a small proportion of its work involves civil fraud investigations. In 2024/25, just 450 new COP 9 and COP 8 cases were opened, reflecting the resource-intensive nature of these enquiries and HMRC’s selective approach.

Given the relatively small number of businesses monitored by LB, practitioners are less likely to encounter routine compliance correspondence from this directorate. Where contact does arise, it is typically structured, relationship-led and mediated through CCMs.

Here is a PDF proof of the article: HMRC’s Customer Compliance Group Explained and our link to a more detailed look at the Customer Compliance Group.

 

Serious investigations

These civil investigations are time intensive and resource hungry, but are usually necessary to combat Tax Fraud or large tax loss risks. HMRC’s Fraud Investigation Service investigators manage these, and have more time, give more attention, and are experienced. Remember, HMRC are seeking a recovery of taxes usually, late payment interest, and typically large penalties, for failing to submit correct tax returns or failing to notify HMRC that taxes were payable in the first place. Allegations of having acted deliberately or dishonestly can be common and HMRC are seeking to publicly name and shame people too.

Code of Practice 9

A Code of Practice 9, or COP9, is a civil investigation of suspected tax fraud, where taxpayers are explicitly accused of having acted dishonestly/with fraudulent intent. Taxpayers are given an opportunity to admit (at a high-level) tax fraud within 60 days in return for being able to make disclosures in much more detail later.

Code of Practice 8

A Code of Practice 8, COP8, is a civil investigation into large amounts of tax at risk, but not necessarily due to tax fraud—but it can include that too. It’s not unusual for these to be used against marketed avoidance schemes or arrangements and bespoke tax planning, where HMRC is likely to have made a discovery about historic tax risks.

The investigators are well prepared to argue they have identified new information and culpability— also triggering penalties. There is little possibility of dissuading them in favour of a COP9-style disclosure report and also typically some span years due to their in-depth nature.

/by