Corporate report

Information about the High-Risk Wealth Programme

Updated 7 December 2022

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The High-Risk Wealth Programme

It is HMRC’s duty to ensure everyone pays the right tax under the law, regardless of wealth or status.

The High-Risk Wealth Programme (HRWP) aims to accelerate the resolution of some of the most complex and highest risk cases within the wealthy customer group.

Overview

HMRC introduced the programme in 2018 to:

  • resolve tax issues and disputes within the wealthy customer population using agreement or litigation
  • reduce risk for the future by influencing individuals to change their behaviour and their approach to tax planning
  • improve the relationship between HMRC and its wealthy customer population
  • improve HMRC’s capability to deal with large and complex tax risks

HMRC chooses cases suitable for the programme by looking at the size of open risks across all taxes. We also consider wealthy individuals’ tax and relationship strategies.

Main elements

The main elements of the programme are:

  • discussions taking place at a senior level between HMRC, wealthy individuals and their advisers
  • HMRC working directly with these stakeholders to investigate and discuss any technical issues
  • HMRC oversight of the programme through our involvement in a cross-directorate steering group
  • the involvement of specialists from across HMRC and, where needed, external legal counsel

Decisions on each case are made in line with the Litigation and Settlement Strategy.

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