Question to the HM Treasury:

To ask Mr Chancellor of the Exchequer, how many tax disputes with large businesses HM Revenue and Customs is engaged in; and what the value is of the tax that is being contested in those disputes.

This question was answered on 17th February 2016
Until 31 March 2014, HM Revenue and Customs’ (HMRC) Large Business Service dealt with the tax affairs of around 800 of the largest businesses in the UK. From 1 April 2014, HMRC’s new Large Business directorate deals with the tax affairs of around 2,000 large businesses.

At 31 December 2015, HMRC had enquiries open with 1,117 of the large businesses dealt with by the Large Business Directorate, covering 3,981 risks with £20.3 billion tax under consideration.

At 31 December 2015, HMRC had enquiries open with 567 of the largest 800 businesses covering 2,826 risks with £16.8 billion tax under consideration.

Tax under consideration is not actual tax either owed or unpaid. Rather, it is a tool which HMRC uses to guide its enquiries to focus on the most significant risks that exist at any particular time. The total is just a snapshot of work in progress and will naturally fluctuate as risks are addressed and new ones taken up.