In the Autumn Budget 2025, the Chancellor announced a new whistleblower reward scheme as part of a package to bolster HMRC’s tax enforcement and recovery powers.
The new, more muscular scheme introduces higher financial rewards to individuals where their disclosures lead to the recovery of significant unpaid tax, marking a departure from HMRC’s long-standing discretionary approach. HMRC estimates (in its annual tax gap report) that the Government loses 47bn a year from unpaid taxes, and this scheme will seek to eat into this number going forward.
We await final details of the scheme but, based on HMRC's original announcement in March 2025, informants will need to provide original, credible, verifiable information that is more than just merely speculative. Any information provided must lead to the recovery of additional tax (or penalties) that would not have otherwise been collected.
This scheme is targeted at serious, high value cases of deliberate wrongdoing. ‘Whistleblowers’ may include individuals with knowledge of unpaid taxes as a result of their role, and will also expand to other general observers. Non-disclosure agreements and confidentiality obligations do not supersede, and cannot prevent, legitimate whistleblowing disclosure.
When plans for a scheme were announced by HMRC in March 2025, it explicitly said it would take inspiration from the successful US and Canadian whistleblower models. The IRS have...
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