Managing serious defaulters

In February 2011, HMRC instigated the Managing Deliberate Defaulters programme as part of their broader work to tackle tax evasion.

On 1 April 2013, HMRC introduced a new monitoring programme targeting serious tax defaulters.

Entry into the programme

An individual will be entered into the programme when they have:

  • To pay a penalty due to a deliberate understatement of tax for years after 6 April 2009
  • Been the subject of a Code of Practice 9 (COP9) investigation irrespective of whether the individual has to pay a penalty due to a deliberate understatement of tax

The new scheme extends the criteria of defaulters who may be subject to enhanced monitoring of their tax affairs to those who have been:

  • Charged a penalty for a deliberate offence under specific tax legislation
  • Identified during a civil fraud investigation as presenting a continuing high-risk
  • Successfully prosecuted for a tax matter
  • Charged a civil evasion penalty for dishonesty
  • Required to give, and has given, security as a guarantee against future default
  • The subject of successful recovery action by an insolvency practitioner

Continued monitoring

HMRC will continue to monitor your tax affairs until they are satisfied that there is no longer a high risk of deliberate or dishonest attempts to get tax affairs wrong. For most people, monitoring will last for between 2 and five years.

HMRC may decide to launch a criminal investigation if a defaulter continues to evade tax whilst in the programme.

Name and shame serious defaulters

The details that may be published include:

  • Name of the individual/company
  • Address
  • Nature of the business
  • Amount of tax evaded
  • The penalty charged for the tax evasion

Disclosure is the best policy

HMRC may not publish details of any tax evaded if you make a full disclosure, either unprompted or immediately on challenge, and cooperate fully with HMRC throughout their investigation.

Why you should contact us

Our experienced team has a significant amount of experience in negotiating with HMRC and we will ensure that any obligations placed on you as part of the Managing Deliberate Defaulters programme are kept to a minimum.

For more information or help from one of our tax investigation specialists, please contact us using our enquiry form.



Sam Inkersole

In 2022, Sam won the Taxation’s Rising Star award at the Taxation Awards in and was named in the Accountancy Age 35 Under 35.

Jon Wedge

While Jon’s client work focuses on the financial services sector, he also oversees the firm’s assurance service, as well as supporting the trainees following in his footsteps.


Elana joined us in 2017 as an ACA trainee, after graduating from Durham University where she had studied languages. She is now a manager in our assurance team.


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