HM Revenue & Customs (HMRC) confirms that they hold the information requested. The information HMRC can disclose is provided below but it is important to set out exactly what these figures mean and what conclusions can be safely drawn from them.
The tax under consideration in an enquiry is initially estimated before any consideration of the specific facts has taken place or before applying any reliefs or allowances. The total arises from all enquiries by the LBS relating to all taxes and duties (including Corporation Tax, VAT, employer duties, excise, and other specific duties such as Petroleum Revenue Tax and Insurance Premium Tax).
It is not tax owed or unpaid - it is a tool which helps LBS managers to better direct resources in order to produce the best results. The success of this approach is evidenced by the progressive rise in the LBS' compliance yield since 2005-06 together with the very significant fall in the number of unproductive ‘small issues' which this approach has enabled HMRC to factor out.
The initial estimate doesn't take into account any reliefs or allowances that might be due, or the full facts or any legal issues. HMRC encourage their people to be expansive in their initial estimate rather than limiting themselves.
In many cases, when HMRC have looked at the full facts it has become clear that there is no further liability at all. HMRC's experience is that that when they look across all relevant issues under enquiry only around half of the estimate of tax under consideration is tax brought into charge.
The figures given are not annual figures. They are a snapshot as at particular dates including enquiries which may have been open for several years.
| Date of Snapshot | Total risks | Tax under consideration |
|---|---|---|
| 30 June 2010 | 3,625 | £31.3 billion |
| 30 June 2011 | 2,595 | £25.0 billion |
