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 of the avoidance behaviours needed to justify putting a large business into special measures, which provides the key barrier to using it.23 HMRC told us that it is considering lowering this threshold, but said that it will approach this very carefully. It said that it does not want to create uncertainty among the large business population and is aware that these kinds of policy changes can have unintended consequences. HMRC plans to consult fully on any changes and told us that any decisions will likely come next year.24 Case duration