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 High Risk Corporates Programme, which HMRC said has helped to change tax behaviours and shift 96% of businesses into a more compliant space. HMRC stated that it considers using special measures on any business that goes into the High Risk Corporates Programme, but argued that the regime’s deterrent effect, in conjunction with HMRC’s operational work, is already successfully driving positive behavioural change among large businesses.21