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 cases.18 Last year, while examining HMRC’s approach to wealthy taxpayers, we found that HMRC was also making little use of its powers in other areas, for example, its power to prosecute those who fail to prevent corporate tax evasion.19 While HMRC believes that egregious non-compliance is rare among the large business population, some stakeholders argue that this power is under-used.20 11 Q 13 12 Qq 13-16 13 Letter from HMRC to the Committee dated 3rd June 2026 14 C&AG’s Report, para 3.14 15 Q 22 16 Q 22 17 C&AG’s Report, para 13 18 C&AG’s Report, para 2.21 19 Committee of Public Accounts, Collecting the right tax from wealthy individuals 20 C&AG’s Report, para 13, LBT0004 9