We asked HMRC whether it would be useful if it segmented the population of wealthy individuals to focus on the very wealthiest taxpayers, and whether it saw different risks from these wealthiest individuals.16 HMRC observed that people’s propensity for risk will vary and that it sees a lot of risk at lower wealth bands, not just from billionaires. HMRC stressed the importance 11 Q 11 12 Q 13 13 Q 77 14 Q 77 15 C&AG’s Report, paras 1, 10, 1.17 16 Qq 26, 50 10 of having a risk model that considers other factors besides pure wealth, such as complexity and opportunity for non-compliance. It said it otherwise might miss those people who are causing more harm to the tax system than just the very wealthy. It compared a very wealthy individual, earning a lot of income through Pay As You Earn and therefore highly visible to HMRC, to another individual with much lower wealth who places properties in very complex offshore trusts and structures which may be indicative of non-compliant behaviour.17 Nevertheless, HMRC acknowledged that it needs to keep its definition of the wealthy population under review and accepted that the case for better segmentation was well made.18