What is HMRC's High Risk Wealthy Programme?

HMRC organises its teams and its efforts to focus on taxpayers who it considers pose greatest risk of not disclosing and paying the correct tax.  HMRC now runs two programmes to focus on corporates and on wealthy individual taxpayers.

These are the High Risk Corporate Programme (HRCP) and the High Risk Wealthy Programme (HRWP), respectively.  The cases are complex, with significant amounts perceived to be at stake.

HRWP & HRCP are effectively ‘super enquiries’ into the affected taxpayers, where HMRC does not open investigations under Code of Practices 8 or 9. They can cover any or all taxes, NICs &/or duties together. HMRC selects taxpayers to include in these programmes, and few are in them at any one time. 

The programmes are led by a Deputy Director in HMRC. An experienced HMRC officer is allocated to lead and co-ordinate the programme’s efforts for each taxpayer. Their role is to:

• Notify the taxpayer & their agent of their inclusion in the programme;
• Collate a team of people in HMRC to work on the case, including technical specialists, to accelerate progress;
• Contact the taxpayer/agent to agree next steps e.g. a meeting to discuss the outstanding issues and any new issues concerning HMRC.   HMRC will expect the taxpayer’s agent to similarly devote significant resources to the case to deal with the issues efficiently, effectively and quickly.
• Ensure frequent contact with the taxpayer/agent to discuss issues and give them an opportunity to demonstrate progress.
• Ensure that all outstanding matters are resolved in accordance with the law, HMRC’s Litigation & Settlement Strategy and its Code of Governance on Resolving Tax Disputes. This includes tax, late payment interest and tax geared penalties for all periods for which HMRC may assess or collect tax/penalties. 

Handling such HRCP/HRWP cases requires a different approach to that which is commonly used for standard enquiries, due to HMRC’s approach and expectations of the resource that needs to be devoted to them in a concentrated period.  It is therefore essential that any taxpayers whose complex affairs are under enquiry already with significant amounts of tax at stake recognise that they could be transferred into the programme at any time.   HMRC will write to you if you are placed in the programme and, at this point, specialist tax dispute resolution advice should be sought (if you are yet to do so) on resolving your enquiries within the programme given HMRC’s expectations of the taxpayer and their adviser.  

The whole process has more in common with a Code of Practice 8 investigation and our Tax Dispute Resolution team is highly experienced in handling this approach.  We have already successfully resolved cases under both these programmes. We add knowledge and expertise of HMRC’s processes, procedures & tax admin law which is essential to successfully resolving these cases. The team can step in as a one-off project to help the individual or corporate through the programme, including alongside other professionals as required.

Contact our local tax advisor Fiona Hall if you have any queries.