Large business tax compliance
Public Accounts Committee
Open
Inquiry
Opened: 12 Dec 2025
Parliament page
Taxes from the nation’s large businesses account for around 40% of the total tax revenue collected by HM Revenue & Customs, while representing less than 0.1% of UK business. HMRC’s large business directorate works with approximately 2,000 of these businesses (typically those with an annual turnover of more than £200m) …
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4
Recommendations
28
Conclusions
1
Report
1
Oral session
2
Letters
1
Event
Activity timeline 4 events
16 Jul
2026
2026
10 Jul
2026
2026
Report published
6 Jul
2026
2026
18 May
2026
2026
Oral evidence
Oral evidence sessions 1 session
18 May 2026
View on parliament.uk
John-Paul Marks · HMRC
John-Paul Marks · HMRC
Jonathan Athow · HMRC
Nicole Newbury · HMRC
Penny Ciniewicz · HMRC
Reports 1 report · click to expand
| Title | HC No. | Published | Items | Response |
|---|---|---|---|---|
| 9th Report - Large business tax compliance | HC 86 | 10 Jul 2026 | 32 | Pending |
Recommendations & Conclusions
32 results
2
Conclusion
9th Report - Large business tax co…
Despite having the power since 2016, HMRC has never put a business into special measures...
Despite having the power since 2016, HMRC has never put a business into special measures and has been slow to review whether the threshold for using it is set at the right level. HMRC says that the special measures regime …
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HM Treasury
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3
Recommendation
9th Report - Large business tax co…
HMRC is taking too long to resolve compliance investigations and bring in the taxes owed...
HMRC is taking too long to resolve compliance investigations and bring in the taxes owed by large businesses. The investigations into large businesses that completed in 2024–25 took on average 17 months to conclude. This is down from the high …
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HM Treasury
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4
Recommendation
9th Report - Large business tax co…
HMRC is placing great reliance on an ambitious IT transformation programme to improve its compliance...
HMRC is placing great reliance on an ambitious IT transformation programme to improve its compliance operations, but it has not made it clear what benefits the large business directorate will see and when. At Spending Review 2025, HMRC received £1.6 …
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HM Treasury
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5
Conclusion
9th Report - Large business tax co…
It is difficult for Parliament and the public to be assured that HMRC settles large...
It is difficult for Parliament and the public to be assured that HMRC settles large and long-running tax disputes fairly and consistently, given it reports only a limited amount of the testing that it carries out. HMRC reports the results …
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HM Treasury
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6
Recommendation
9th Report - Large business tax co…
Even with a new international minimum tax rate being implemented, the scale of risks posed...
Even with a new international minimum tax rate being implemented, the scale of risks posed by large multinationals diverting profits across borders remains significantly high. International tax risks, including businesses artificially shifting their profits to lower-tax jurisdictions, account for £21 …
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HM Treasury
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7
Recommendation
9th Report - Large business tax co…
The UK tax system is incredibly complex and there is more for HMRC to do...
The UK tax system is incredibly complex and there is more for HMRC to do to reduce the compliance burden on large businesses. Around half of the large business tax gap results from large businesses interpreting tax law differently to …
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HM Treasury
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1
Conclusion
9th Report - Large business tax co…
On the basis of a report by the Comptroller and Auditor General, we took evidence...
On the basis of a report by the Comptroller and Auditor General, we took evidence from HM Revenue & Customs (HMRC) on large business tax compliance.1
HM Treasury
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8
Conclusion
9th Report - Large business tax co…
Given the high return on investment HMRC gets from its compliance work with large businesses,...
Given the high return on investment HMRC gets from its compliance work with large businesses, we asked it why it did not spend more on the large business directorate. HMRC told us that it was recruiting 5,500 full- time equivalent …
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HM Treasury
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9
Conclusion
9th Report - Large business tax co…
HMRC is considering expanding the cooperative compliance model to businesses that currently sit within its...
HMRC is considering expanding the cooperative compliance model to businesses that currently sit within its mid-sized business team.14 HMRC told us that over the next 12 to 18 months it is going to explore what aspects of cooperative compliance might …
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HM Treasury
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10
Conclusion
9th Report - Large business tax co…
Since 2016, HMRC has had the power to sanction large businesses who display continued poor...
Since 2016, HMRC has had the power to sanction large businesses who display continued poor behaviour as part of a special measures regime.17 HMRC has never used this power, although it has considered doing so in a small number of …
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HM Treasury
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11
Conclusion
9th Report - Large business tax co…
HMRC told us that the special measures regime was designed to be a deterrent.
HMRC told us that the special measures regime was designed to be a deterrent. It said it uses this alongside a package of other measures to incentivise large businesses to plan their tax affairs responsibly. One such measure is the …
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HM Treasury
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12
Conclusion
9th Report - Large business tax co…
Given that HMRC has never used the special measures regime, we asked HMRC how it...
Given that HMRC has never used the special measures regime, we asked HMRC how it can know that it is an effective deterrent. While HMRC recognised that it could not demonstrate that special measures has had a deterrent effect in …
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HM Treasury
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13
Conclusion
9th Report - Large business tax co…
While HMRC believes that the special measures regime has served as an effective deterrent, it...
While HMRC believes that the special measures regime has served as an effective deterrent, it is exploring how it might change it to make it more effective in future. HMRC said there is a very high legal threshold in terms …
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HM Treasury
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14
Conclusion
9th Report - Large business tax co…
For those investigations into large businesses that completed in 2024–25, it took HMRC 17 months...
For those investigations into large businesses that completed in 2024–25, it took HMRC 17 months on average to close each case. This is down from 35 months for the cases that closed in 2021–22, during the COVID-19 pandemic. However, in …
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HM Treasury
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15
Conclusion
9th Report - Large business tax co…
We asked HMRC what further work it was doing to reduce the time it takes...
We asked HMRC what further work it was doing to reduce the time it takes to close its investigations into large businesses. HMRC said that the average case duration is decreasing, and is expected to drop to 16 months once …
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HM Treasury
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16
Conclusion
9th Report - Large business tax co…
HMRC explained that when litigation is involved, there are factors outside its control and it...
HMRC explained that when litigation is involved, there are factors outside its control and it must work with the court system to resolve cases. HMRC said it is focused on reaching agreement with businesses and avoiding litigation where it can, …
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HM Treasury
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17
Conclusion
9th Report - Large business tax co…
HMRC has a goal to modernise its IT infrastructure by 2030.
HMRC has a goal to modernise its IT infrastructure by 2030. At Spending Review 2025, it received an additional £1.6 billion from 2026–27 to 2028–29 to achieve this. Through this investment, HMRC aims to migrate legacy data stores to a …
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HM Treasury
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18
Conclusion
9th Report - Large business tax co…
We asked HMRC when it expects to see the benefits of the extra investment in...
We asked HMRC when it expects to see the benefits of the extra investment in its IT. HMRC told us that by the end of the Spending Review period it wants to be a digital first organisation, with 90% of …
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HM Treasury
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19
Conclusion
9th Report - Large business tax co…
HMRC explained its IT transformation is in its early stages.
HMRC explained its IT transformation is in its early stages. It said it reviews its portfolio of programmes every month against milestones, deliverables and benefit forecasts. HMRC said that it is on track to hit the high-level milestones it has …
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HM Treasury
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20
Conclusion
9th Report - Large business tax co…
Disputes between HMRC and large businesses over how much tax is owed can be resolved...
Disputes between HMRC and large businesses over how much tax is owed can be resolved either through settlement or litigation. HMRC’s decisions on whether to settle are framed by its litigation and settlement strategy, which states that HMRC will not …
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HM Treasury
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21
Conclusion
9th Report - Large business tax co…
We asked HMRC whether it could assure Parliament and the public that it had operated...
We asked HMRC whether it could assure Parliament and the public that it had operated fairly and consistently in two, large, well-publicised tax dispute cases (with General Electric and Glencore). It said that the duty to protect taxpayer confidentiality is …
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HM Treasury
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22
Conclusion
9th Report - Large business tax co…
In correspondence received after the evidence session, HMRC told us that it uses media campaigns...
In correspondence received after the evidence session, HMRC told us that it uses media campaigns and its Strengthened Reward Scheme to incentivise the public and informants to come forward with information of serious non- compliance, including in the large business …
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HM Treasury
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23
Conclusion
9th Report - Large business tax co…
HMRC said that its governance processes are set out in its litigation and settlement strategy.
HMRC said that its governance processes are set out in its litigation and settlement strategy. It told us it is confident these processes are robust, and is constantly looking for evidence that shows it is acting fairly and consistently in …
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HM Treasury
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24
Conclusion
9th Report - Large business tax co…
Large businesses artificially shifting profits from one country to another to pay less tax is...
Large businesses artificially shifting profits from one country to another to pay less tax is a significant tax risk.35 We asked HMRC how it could assure us that it fairly and consistently pursues such businesses. HMRC responded that it is …
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HM Treasury
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25
Conclusion
9th Report - Large business tax co…
The international nature of large businesses presents high risks to tax revenues, including from profit...
The international nature of large businesses presents high risks to tax revenues, including from profit shifting. Nearly 90% of large businesses operate internationally and of the £70.1 billion of tax under consideration in 2025 as part of investigations into large …
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HM Treasury
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26
Conclusion
9th Report - Large business tax co…
HMRC recognises that the Pillar 2 arrangements will introduce added complexity to the tax affairs...
HMRC recognises that the Pillar 2 arrangements will introduce added complexity to the tax affairs of those large businesses which fall within its remit, and that businesses will need to compute their Corporation Tax differently.39 HMRC has forecast that complying …
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HM Treasury
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27
Conclusion
9th Report - Large business tax co…
Those businesses that fall under Pillar 2 will need support to comply with the new...
Those businesses that fall under Pillar 2 will need support to comply with the new requirements. HMRC told us that it has been working with international partners and the OECD to ensure that it has clear legislation and guidance in …
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HM Treasury
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28
Conclusion
9th Report - Large business tax co…
In January 2026, countries signed up to Pillar 2 negotiated a ‘side-by-side’ agreement with the...
In January 2026, countries signed up to Pillar 2 negotiated a ‘side-by-side’ agreement with the United States (US). As a result, US-headquartered businesses, and their foreign subsidiaries, will remain subject to US minimum tax rules.43 We asked HMRC what impact …
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HM Treasury
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29
Conclusion
9th Report - Large business tax co…
Legal interpretation is a primary driver of the large business tax gap, accounting for around...
Legal interpretation is a primary driver of the large business tax gap, accounting for around 50%. This occurs when HMRC and a large business have different interpretations of the law, and therefore a different understanding of how much tax is …
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HM Treasury
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30
Conclusion
9th Report - Large business tax co…
We asked HMRC why it cannot simplify tax rules to make it easier for businesses...
We asked HMRC why it cannot simplify tax rules to make it easier for businesses to comply. HMRC said that it does make it simpler where it can. However, it said that sometimes the complexity of the tax system reflects …
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HM Treasury
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31
Conclusion
9th Report - Large business tax co…
The complexity in the tax system also creates additional burdens for both HMRC and taxpayers.
The complexity in the tax system also creates additional burdens for both HMRC and taxpayers. Only 49% of the large businesses surveyed by HMRC in 2024 felt the administrative burdens were reasonable; 29% viewed the burden as unreasonable.50 We asked …
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HM Treasury
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32
Conclusion
9th Report - Large business tax co…
HMRC told us that it aims to reduce the compliance burden on customers by automating...
HMRC told us that it aims to reduce the compliance burden on customers by automating the collection of data. It said that this will allow it to assess risks across businesses more accurately and so avoid investigations in the future. …
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HM Treasury
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Correspondence 2 letters
16 Jul 2026
To committee
Letter from the Chair to the Permanent Secretary of HM Revenue & Customs relating to Loan Charge, dated 16 July 2026
Parliament page
6 Jul 2026
To committee
Letter from the Chief Executive and First Permanent Secretary at HMRC relating to Large Business Tax Compliance, 3 June 2026
Parliament page