CH820000 - Agent operational guidance: High Volume Agents
Source: gov.uk (2025-09-01)


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High Volume Agents (HVAs) deal with large numbers of clients, often for a short time only, and make requests for repayments or submit returns that generate repayments. Often the returns are voluntary returns. Voluntary returns are returns received from customers or agents, where HMRC have not given a notice to the customer to make the return.

HMRC's long standing policy of treating them as statutory returns has been put beyond doubt, as from 12 February 2019 new law was introduced which has retrospective and prospective effect.

All voluntary returns should now be treated as having been made in response to a notice to file which was given to the person on the same date the return was received by HMRC, see SAM121140 (https://www.gov.uk/hmrc-internal-manuals/self-assessment-manual/sam121140).

HVAs usually
- provide services on a commission or ‘no repayment no fee’ basis
- target clients in a specific trade or industry, for example the construction industry
- submit high numbers of requests for repayments relating to expenses/deductions incurred in their clients’ employment or trade
- receive the tax repayment as a nominee for their client
- are not members of a professional taxation accountancy body, although some of their staff may hold professional qualifications
- have little or no face to face contact with their clients as much of their business is carried out electronically.
A request for a repayment can be made using any of the following
- P87
- stand-alone claim by correspondence
- Self Assessment tax return
- voluntary return.
The range of expenses/deductions that result in a repayment usually include
- travel
- subsistence
- overnight accommodation
- cost of food
- use of home
- wife, civil partner or relative’s wages
- cost of tools
- protective or specialist clothing
- laundry
- telephone costs.
Many HVAs have trained staff who are fully aware of the legitimate expenses/deductions that can be made in their clients’ business area. They prepare accounts accurately and swiftly for a competitive price. However, based on evidence that HMRC has gathered since 2009, many HVAs present a high risk to both HMRC and their clients.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

HMRC will continue to address the issues specific HVAs present through an ongoing programme of risk assessment and agent meetings.

In any case involving an HVA where you identify poor technical ability, encounter rude, abusive, threatening or violent behaviour or you identify suspicious repayment or registration activity or dishonest conduct, you must contact the Agent Compliance Team (ACT) (mailto:7821989) (link sends e-mail), see CH860000 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch860000).