Tax under consideration - enquiries by type of risk

Request

The 'tax under consideration figure' for enquiries by Large Business Service (LBS) by type of risk as used internally.

Response

HM Revenue & Customs (HMRC) confirms that it holds the information requested but some of it is being withheld as disclosure would, or would be likely to, prejudice the assessment or collection of tax.

However, to be helpful, HMRC is prepared to provide some information, within the scope of this request, at a level of detail that would not be able to be used by others to avoid or evade tax, and this is set out below.

It is important to explain exactly what these figures mean and what conclusions can be safely drawn from them.

  • The data shown, and its value, is a snapshot at the 31 March 2011 of the open operational risks under consideration in LBS. These are not annual figures and include enquiries which may have been open for several years. The distribution and value of open risks changes with time as new risks are identified and others closed. The distribution and value shown cannot be taken to be representative over a period of time and may be significantly different at another point in time.
  • The values shown are 'Current Tax under Consideration (CTUC)'. This is initially estimated before any consideration of the specific facts has taken place or before applying any reliefs or allowances. 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.
  • 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.
Type of risk Sum of current tax under consideration at 31 March 2011
Accounting Standards £256,980,905
Approvals, Authorisations and Registrations £19,729,673
Capital Gains £377,012,912
Controlled Foreign Companies £3,749,000,000
Construction Industry Scheme (CIS) £22,828,774
CT Issue regarding Employment £30,388,791
CT on VAT £153,584,014
Customs Procedures, Imports, Exports & Warehousing £51,126,961
Employee and Director Issues £281,707,705
Expenditure, Expenses & Apportionments £249,122,768
Financial Instruments £2,306,537,663
Fleming £1,113,894,807
Group Litigation Orders £1,414,423,660
Input Tax Overclaimed £135,660,999
Intellectual Property £138,033,095
International £5,245,739,800
Leasing £1,855,074,574
Management expenses £173,150,692
Mis-application of VAT Reliefs £149,241,601
Output Tax Under declared £638,025,039
P11D/ Class 1A NIC £11,057,818
Partial Exemption £119,746,192
Reliefs, Rebates and Exemptions £817,918,450
Revenue Payment and Claims £68,221,807
Schemes/Arrangements £79,254,533
Schemes/Trusts £660,844,645
Stamp Duty Land Tax, Stamp Duty Reserve Tax £76,517,014
Serious Non-Compliance £86,162,883
Statutory Allowances / Reliefs £2,625,003,557
Timely and Accurate Submission of Declarations £40,003,399
Trading, Computation of Profits, Receipts and Deductions £918,095,238
Transfer Pricing and Thin Cap £679,364,136
Valuations £51,124,384
Other Risks £921,090,961
Grand Total £25,515,669,450