HMRC puts 200 billionaires on UK tax crackdown hitlist

HM Revenue and Customs, or HMRC, is the UK authority responsible for collecting taxes and checking whether people pay what they owe. The article describes a new role for particularly complex taxpayers: the customer compliance manager, or CCM.

Each billionaire with a UK tax footprint will be assigned a CCM. The manager will offer voluntary discussions before the billionaire files tax returns. These conversations aim to create a shared understanding of the person’s UK tax affairs, including activities involving several taxes, companies or countries.

The arrangement is meant to make later contact more focused and proportionate. It also gives HMRC earlier engagement with taxpayers whose affairs may be difficult to assess. The authority says billionaires can require coordinated handling because their financial arrangements often cross jurisdictions. HMRC is introducing the managers as part of a wider effort to reduce the wealthy tax gap and raise additional revenue.

HMRC is assigning a dedicated customer compliance manager to more than 200 billionaires who have a UK tax footprint. This is the first time the authority has compiled a list of billionaires required to pay UK tax, whether or not they formally live in Britain.

The managers will offer voluntary discussions before tax returns are filed. HMRC says this should improve its understanding of complex affairs and make later compliance work more focused. The authority is also introducing analytics, automated triggers and artificial intelligence to identify risks earlier among wealthy people.

HMRC expects these measures to contribute at least £500m to a wider government goal of raising £10bn in extra tax revenue by 2030. The estimated wealthy tax gap was £3.6bn in 2024–25. That represents 6% of the total tax gap across the UK’s tax-paying population.

A UK tax footprint means a person has financial or economic connections that create UK tax responsibilities. Formal residence is only one factor. Someone living overseas may still earn income from the UK, own UK-related assets, operate through UK companies or conduct business activity connected with the country.

For example, a billionaire could live abroad while holding UK investments and receiving income from them. That person might also use several companies in different jurisdictions. HMRC would need to examine the whole arrangement to determine which parts create UK tax obligations and whether the relevant income or assets were disclosed.

The article does not list every type of UK connection that creates a tax footprint. It does state that billionaires can be required to pay UK tax regardless of formal residence. HMRC’s new managers are intended to clarify these cross-border affairs before filing and improve compliance.

The wealthy tax gap is the difference between the tax wealthy people should pay and the tax they actually pay. In the article, it is linked to cases where rich individuals fail to disclose all their assets to HMRC. This can leave public revenue uncollected.

HMRC defines wealthy people for its new technology programme as those with income above £200,000 or assets exceeding £2m in any of the past three years. For example, someone meeting either threshold might have complex investments or property that HMRC needs to assess more closely.

The wealthy tax gap was estimated at £3.6bn for 2024–25. HMRC said this equalled 6% of the total tax gap across the UK’s entire tax-paying population. Its planned compliance work is expected to contribute at least £500m toward a broader goal of raising £10bn in additional tax revenues by 2030.

If HMRC’s systems identify undeclared income or assets, the taxpayer could face more focused compliance activity. The article does not specify a particular penalty or enforcement outcome. It does make clear that the technology is intended to identify emerging risks earlier and target checks where they will have the greatest impact.

For example, automated triggers might flag information that does not match a wealthy person’s reported tax position. Advanced analytics or artificial intelligence could then help HMRC decide which case needs attention. Officials might contact the taxpayer, request explanations or examine connected entities and jurisdictions.

The immediate purpose is earlier detection and better targeting, not automatic guilt. A risk signal would need to be considered through HMRC’s compliance process. If undeclared tax were established, the taxpayer could be required to address the shortfall under applicable UK rules. The article gives no further details about penalties.

A billionaire may hold different types of wealth and receive different types of income. Those arrangements can involve personal income, investments, companies, property and other entities. When these interests operate in different countries, each connection can create separate reporting or tax questions.

For example, one person might live in one country, own a company in another, receive investment income from the UK and hold assets through several entities. HMRC would need to understand how the pieces connect, which taxes apply and what information has been disclosed. The article identifies this combination of taxes, entities and jurisdictions as a central challenge.

This complexity is why HMRC is assigning customer compliance managers to billionaires with UK tax footprints. The managers are meant to encourage early, voluntary discussions before filing. HMRC says coordinated engagement can build a shared understanding and make later compliance work more focused and proportionate.

The article does not explain how countries divide taxing rights. In general, governments use domestic tax law and international agreements to assess a person’s residence, the source of income, the location of assets and where business activity occurs. These rules help determine whether income or gains are taxable in one country, another, or both.

For example, a person may live in one country but earn rent from property in another. The property’s country commonly claims taxing rights over that source income, while the person’s residence country may also tax worldwide income. A tax treaty can assign priority or provide a credit so the same income is not taxed twice.

The exact result depends on the countries involved, the type of income or asset and the person’s legal status. This is why cross-border cases can be complicated. In the article, HMRC highlights jurisdictions as one reason billionaire affairs need coordinated engagement, but it does not set out specific treaty rules.