As at 13 May 2022, HMRC had seven investigations and 21 potential investigations into facilitation of tax evasion across a range of business sectors and business sizes.
HMRC has allocated additional roles to fraud investigation since the introduction of the Criminal Finances Act 2017 and HMRC case managers have been trained to discuss the CCO with large businesses. It also forms part of HMRC’s Business Risk Review checklist.
New cases are often being identified through HMRC’s usual tax evasion investigations under either civil or criminal powers. Where tax evasion is found to have occurred, HMRC then considers whether or not the tax evasion was facilitated by an ‘associated person’ of a relevant entity. By tracing the tax evasion through to an entity, HMRC is then able to enquire as to whether or not that entity has done a CCO risk assessment and test its prevention procedures.