Tackling the tax gap

Public Accounts Committee Closed Inquiry
Opened: 27 Jul 2020 Closed: 9 Nov 2020 Parliament page
The “tax gap” is the difference between the amount of tax that should, in theory, be paid to HMRC, and what is actually paid. HMRC relies heavily on taxpayers - individuals and organisations - reporting their finances and paying their taxes in line with the rules. In the last financial … Read more
6 Recommendations
14 Conclusions
1 Report
1 Oral session
2 Letters
1 Event
Oral evidence sessions 1 session
Tackling the tax gap
Beth Russell · Her Majesty's Treasury Jim Harra · HMRC Penny Ciniewicz · HMRC
Recommendations & Conclusions
20 results
2 Recommendation Not Addressed
Twentieth Report - Tackling the ta…
HMRC does not know the relative size of tax gaps in the four nations of...
HMRC does not know the relative size of tax gaps in the four nations of the UK or across different industries. HMRC already publishes breakdowns of the tax gap by taxpayer group, tax type and behaviour. However, HMRC does not … Read more
Government Response
The government's response discusses funding decisions for the Towns Fund and Levelling Up Fund, providing no comment on HMRC's ability to estimate tax gaps in the four UK nations.
HM Treasury
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20 Recommendation Rejected
Twentieth Report - Tackling the ta…
In addition, HMRC does not publish any tax gap analysis for different types of industry.
In addition, HMRC does not publish any tax gap analysis for different types of industry. For example, HMRC has not published an estimated tax gap for the construction industry despite introducing the construction industry scheme to deal with high levels … Read more
Government Response
The government rejects the recommendation to include tax gap analysis by industrial sector due to data and modelling limitations, feasibility issues, and the high level of assumption required, and implicitly rejects analysis for the four nations for similar reasons.
HM Treasury
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3 Recommendation Accepted
Twentieth Report - Tackling the ta…
HMRC does not include sophisticated and undesirable tax planning by the wealthy and large businesses...
HMRC does not include sophisticated and undesirable tax planning by the wealthy and large businesses in its estimates of the tax gap. HMRC’s tax gap measures the uncollected revenue due to taxpayers’ non-compliance with existing rules. HMRC does not assess … Read more
Government Response
The government states it agrees with the recommendation and claims it is implemented, explaining that it already provides an estimate of the 'avoidance tax gap' for revenue loss when taxpayers do not follow the spirit of the law, as detailed in its publication.
HM Treasury
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4 Recommendation Not Addressed
Twentieth Report - Tackling the ta…
Although HMRC has yet to see the full effects of COVID-19 on taxpayer compliance, it...
Although HMRC has yet to see the full effects of COVID-19 on taxpayer compliance, it is already estimating up to £3.5 billion of fraud and error in furlough payments and has seen a significant drop in compliance yield in the … Read more
Government Response
The government's response is irrelevant to the recommendation, discussing an annual update and monitoring of 'the Fund' rather than explaining how HMRC will change its compliance approach in light of COVID-19.
HM Treasury
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5 Recommendation Accepted
Twentieth Report - Tackling the ta…
It is not clear that Making Tax Digital will help reduce the tax gap or...
It is not clear that Making Tax Digital will help reduce the tax gap or taxpayer costs at a time when individual taxpayers and small businesses are under considerable pressure. HMRC’s primary objective for the ‘Making Tax Digital’ programme is … Read more
Government Response
The government agrees with the recommendation with a target implementation date of Summer 2021, and HMRC is engaging with stakeholders to understand and minimise MTD costs, with revised estimates to be published.
HM Treasury
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6 Recommendation Accepted
Twentieth Report - Tackling the ta…
HMRC’s plans to tackle the part of the tax gap attributable to small businesses are...
HMRC’s plans to tackle the part of the tax gap attributable to small businesses are made more difficult by the need to help those businesses survive the impact of the COVID-19 pandemic. HMRC estimates that 43% of the tax gap … Read more
Government Response
The government accepts the recommendation, confirming that HMRC wrote to the Committee on 10 November 2020, explaining its approach to balancing tax gap efforts with supporting small businesses impacted by COVID-19, and published an issue briefing detailing this.
HM Treasury
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1 Conclusion Not Addressed
Twentieth Report - Tackling the ta…
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 (the Department) and HM Treasury on tackling the tax gap.2
Government Response
The government's response provides an introductory overview of HMRC's tax system responsibilities and the tax gap, rather than addressing the committee's factual statement about taking evidence.
HM Treasury
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7 Conclusion Rejected
Twentieth Report - Tackling the ta…
HMRC measures the additional amount it generates by tackling tax avoidance, evasion and non-compliance, known...
HMRC measures the additional amount it generates by tackling tax avoidance, evasion and non-compliance, known as compliance yield. In its 2018–19 Annual Report, HMRC reported £34.1 billion of compliance yield, compared with £30.3 billion in the previous year.12 HMRC confirmed … Read more
Government Response
The government rejects the implicit suggestion of providing confidence intervals for compliance yield, explaining that due to complexity and varied methodologies, a robust method would be complex, assumption-based, and of limited insight.
HM Treasury
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8 Conclusion Rejected
Twentieth Report - Tackling the ta…
HMRC publishes a breakdown of the tax gap by taxpayer group, tax type and behaviour.16...
HMRC publishes a breakdown of the tax gap by taxpayer group, tax type and behaviour.16 HMRC told us that it uses the outcomes of its tax gap analysis as indicators 7 Q 23; C&AG’s Report, para 1.12 8 Qq 23–25 … Read more
Government Response
The government rejects the implicit recommendation for tax gap analysis in the four nations due to data and modelling limitations, stating that current methods do not comprehensively allow for such subgroup analysis, though it disaggregates the oils tax gap for Northern Ireland where feasible.
HM Treasury
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9 Conclusion Rejected
Twentieth Report - Tackling the ta…
It also transpired, when we questioned the Department about the size of the tax gap...
It also transpired, when we questioned the Department about the size of the tax gap in the construction industry, that HMRC does not assess and publish the relative size of the tax gap across different industries. The construction industry has … Read more
Government Response
The government disagrees with the implied recommendation to assess and publish the tax gap across different industries, explaining that current models, data, and resources do not allow for comprehensive or precise industry-specific analysis.
HM Treasury
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10 Conclusion Accepted
Twentieth Report - Tackling the ta…
HMRC’s estimate of the tax gap includes both non-compliance with the letter of the law,...
HMRC’s estimate of the tax gap includes both non-compliance with the letter of the law, such as tax evasion, and non-compliance with the spirit of the law, such as tax avoidance.22 We asked the Department the extent to which the … Read more
Government Response
The government confirms that it already provides an estimate of the 'avoidance tax gap,' defined as revenue loss from taxpayers not following the spirit of the law, detailing how this is captured in its publications.
HM Treasury
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11 Conclusion Rejected
Twentieth Report - Tackling the ta…
HMRC’s tax gap does not capture the ‘policy gap’, which HMRC characterised as the tax...
HMRC’s tax gap does not capture the ‘policy gap’, which HMRC characterised as the tax loss that is not due, but which might be due if the tax rules could be tightened up. HMRC confirmed to us that there is … Read more
Government Response
The government rejects the idea of measuring tax loss from 'undesirable sophisticated tax planning' due to definitional and feasibility issues, though it states it already estimates the avoidance tax gap (bending rules, not the spirit of the law).
HM Treasury
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12 Conclusion Acknowledged
Twentieth Report - Tackling the ta…
The COVID-19 pandemic may increase the risks of non-payment of taxes and more people may...
The COVID-19 pandemic may increase the risks of non-payment of taxes and more people may operate in the deliberately hidden part of the economy.26 We asked HMRC about its assessment of the impact of the pandemic on the size of … Read more
Government Response
The government states it regularly publishes updates on its changed compliance approach due to COVID-19 and plans to publish a full estimate of error and fraud, which relates to the context of the pandemic's impact on tax collection discussed in the conclusion.
HM Treasury
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13 Conclusion Accepted in Part
Twentieth Report - Tackling the ta…
During the pandemic, HMRC told us that it had to redeploy its resources from frontline...
During the pandemic, HMRC told us that it had to redeploy its resources from frontline activities, such as collection of tax, to work supporting taxpayers through the COVID support schemes. HMRC expects a reduction on compliance yield in 2020–21 compared … Read more
Government Response
The government states it regularly publishes updates on its changed compliance approach due to COVID-19 and plans to publish a full estimate of error and fraud in COVID-19 support schemes by late 2021, a timeline under review.
HM Treasury
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14 Conclusion
Twentieth Report - Tackling the ta…
HMRC explained to us that its overall approach to ensuring taxpayers’ compliance with the tax...
HMRC explained to us that its overall approach to ensuring taxpayers’ compliance with the tax laws is predicated on promoting voluntary compliance through promoting trust in the tax system and supporting taxpayers that want to comply. It aims to deter … Read more
HM Treasury
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15 Conclusion Accepted
Twentieth Report - Tackling the ta…
HMRC is implementing an ambitious initiative, Making Tax Digital, to help tackle error and failure...
HMRC is implementing an ambitious initiative, Making Tax Digital, to help tackle error and failure to take reasonable care, particularly in the small business population. Small businesses accounted for the largest share of the tax gap (£13.4 billion; 43%) in … Read more
Government Response
The government agrees with the committee's observation, reiterating its existing plans to expand Making Tax Digital to all VAT payers from April 2022 and to businesses/landlords with income over £10,000 from April 2023, while noting ongoing stakeholder engagement to minimise costs.
HM Treasury
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16 Conclusion Accepted
Twentieth Report - Tackling the ta…
We questioned the Department about the effectiveness of Making Tax Digital in closing the tax...
We questioned the Department about the effectiveness of Making Tax Digital in closing the tax gap, particularly in tackling tax evasion. HMRC explained that the programme is not designed to tackle tax evasion by small businesses. Other solutions are required … Read more
Government Response
The government agrees and outlines its ongoing plans for the expansion of Making Tax Digital (MTD) to more taxpayers and tax types by April 2023, noting its role in reducing errors and improving productivity, with continued engagement on cost estimates.
HM Treasury
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17 Conclusion Not Addressed
Twentieth Report - Tackling the ta…
We also received written evidence from the Chartered Institute of Taxation, which highlighted the findings...
We also received written evidence from the Chartered Institute of Taxation, which highlighted the findings of a survey of businesses and agents with an interest in the programme that they had carried out jointly with the Association of Taxation Technicians … Read more
Government Response
The government's response, which states agreement with a recommendation and details its actions on MTD costs, does not directly address the committee's conclusion that survey findings indicated Making Tax Digital compliance costs had far exceeded government estimates.
HM Treasury
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18 Conclusion Accepted
Twentieth Report - Tackling the ta…
Small businesses accounted for the largest share of the tax gap in 2018–19.42 The tax...
Small businesses accounted for the largest share of the tax gap in 2018–19.42 The tax gap attributable to small businesses was 43% (£13.4 billion) of the total tax gap in 2018–19 and has remained fairly stable as a percentage of … Read more
Government Response
The government agrees and states it has implemented a strategy to balance tackling the tax gap in small businesses with providing support during COVID-19, having published an issue briefing outlining its approach.
HM Treasury
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19 Conclusion Acknowledged
Twentieth Report - Tackling the ta…
We asked HMRC whether it is doing enough to tackle small businesses that operate in...
We asked HMRC whether it is doing enough to tackle small businesses that operate in the hidden economy and deliberately evade their responsibilities. HMRC told us that about 8,000 of its staff concentrate on ensuring compliance in the small business … Read more
Government Response
The government states it agrees with the implied recommendation and has implemented its approach to supporting small businesses during COVID-19, having published an HMRC issue briefing on how it will continue to support customers and the economy.
HM Treasury
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Government Response AI assessment · 19 of 6 classified

Total 6 recs + 14 conclusions
Correspondence 2 letters
21 Jun 2021 Correspondence from Jim Harra, Chief Executive and First Permanent Secretary, re Consequential impacts on historical tax gap estimates from revisions to tax receipts, dated 10 June 2021
Parliament page
3 Nov 2020 Correspondence to HM Revenue and Customs on the Tackling the tax gap report, dated 22 October 2020
Parliament page