Even among the wealthy population there are vast disparities in wealth and circumstance, making it likely that more tax is at risk for the wealthiest taxpayers. The population of wealthy taxpayers that HMRC’s wealthy team administers is getting bigger, up from 700,000 individuals in 2019–20 to 850,000 individuals in 2023–24. HMRC treats wealthy individuals as one single group and its risk assessment process does not segment wealthy individuals according to levels of wealth. HMRC says that as people’s propensity for risk will vary, it must consider other factors besides pure wealth, such as complexity and opportunity for non-compliance. It says it finds some billionaires have quite straightforward tax planning, while some millionaires with much lower wealth will have set up very complex offshore trusts and structures. But it is worth noting, for example, that the value of tax associated with a billionaire could 3 be a hundred times greater than a high net worth individual (assets of £10 million or more), due to the difference in wealth. HMRC deploys its customer compliance managers according to those taxpayers who pose the most risk and says that these managers typically end up working on cases relating to individuals with wealth above £10 million. Nevertheless, HMRC acknowledges it needs to improve its data and risking and may need to make changes to its risk model. recommendation a. As part of its plan for increasing yield from wealthy taxpayers domestically and offshore, HMRC should review whether segmenting its wealthy customer group according to different levels of wealth and complexity would help it to assess and then target the most significant risks. b. As part of its consideration, HMRC should estimate the value of tax at risk within the wealthy taxpayer base and write to us with the results.