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HMRC Tax Rewards Program May Preview New Whistleblower Era in UK and EU, Says Neil Getnick in Corporate Crime Reporter Interview

All News December 16, 2025

Managing Partner Neil Getnick was interviewed by the Corporate Crime Reporter, where he discussed his take on the United Kingdom’s strengthened tax informant rewards program launched by His Majesty’s Revenue and Customs (HMRC).  In the interview and accompanying article, Neil delves into HMRC’s new program, why it has the “possibility of much more substantial rewards” for those reporting tax fraud in the UK, and how it is set up for success.

The HMRC’s new tax rewards program allows individuals to receive an award for report serious tax avoidance in the UK.  In particular, individuals may receive 15% – 30% of HMRC’s recovery if the HMRC collects at least £1.5 million ($2 million) in tax based on the information they provide.  Though the HMRC has had an informant rewards program for many years, “now they’ve really upped their game by following the model of the US IRS whistleblower law and program.”

In explaining the HMRC program’s high potential for success, Neil detailed the history of the federal False Claims Act and whistleblower programs in the United States.  Neil noted that when the 1986 amendments to the False Claims Act went into effect recoveries skyrocketed, and “[s]ince then there’s been more than $55 billion dollars” recovered to date.  That success gave rise to “no less than 36 state False Claims Act Laws” and numerous whistleblower programs, including the IRS whistleblower program.  “The success of these programs is a matter of building strength upon strength and seeing very significant recoveries coming into the US and State treasuries as a result.”

Neil further explained that the history of whistleblower laws and programs in the United States provides a window into elements that distinguish the most successful whistleblower programs, which HMRC has incorporated into its program:

  1. Threshold: “[A] bottom-line number that you have to reach in order for the matter to be jurisdictionally permissible.”  Thresholds are “very important [because they] allow[] the ability to cull out de minimis matters and focus instead on matters with potential for high returns.
  2. A floor and ceiling for the award: “[T]he understanding that there’s going to be a minimum percentage award, a floor, which is very important to incentivize whistleblowers and their counsel to file, and at the same time to have a ceiling, which establishes a percentage limit which protects the public fisc.”
  3. No caps: “In other words, beyond the percentage limits, there’ll be no cap on the size of the award.”
  4. A public-private partnership: “The most successful results under these programs are achieved when the government agency and the informant and counsel work together to maximize the recovery. To be sure, the government agency is in charge of the matter, with the informant and counsel providing support as requested. This arrangement allows the government to leverage those private resources with increasing efficiency and effectiveness.”
  5. Embrace: “To be fully successful, it’s essential that the government agency embraces such a program and does not just tolerate or resist it. And from what I have seen, HMRC appears poised to embrace this program and to take full advantage of the information and resources which will be coming its way.”

Neil also explained how HMRC’s program likely foreshadows a new era of whistleblower programs in the UK and European Union, both of which have traditionally been resistant to whistleblower rewards.  The UK’s Serious Fraud Office (SFO) is reportedly “poised to put in a program of their own” and “word is that for the first time, the EU is taking a significant interest in all of this as well.”  Although “[i]t’s too early to say exactly what shape that will take going forward,” if the SFO and EU follow HMRC’s lead “that may very well be the most significant contribution to the fight against international economic crime that we will have seen so far in this century.”

If you think you may have information relating to tax fraud in the UK, contact us.