A New Era for UK Tax Enforcement: Inside HMRC’s “Breakthrough” Informant Reward Program

For decades, the global gold standard for fighting financial crime has been the U.S. whistleblower reward model—a system that incentivizes insiders to report high-value fraud in exchange for a percentage of the funds recovered.

Now, the UK is stepping into the ring.

In our latest webinar, “Understanding the UK’s Strengthened Whistleblower Reward Program,” the National Whistleblower Center brought together leading experts to unpack this historic shift. We were joined by Anthony Rodgers, the Operational Lead for the new HMRC program; Eliza Lockhart, Research Fellow at RUSI; and Dean Zerbe, a top tax whistleblower attorney.

If you are a practitioner, a potential informant, or a compliance officer, this is a sea change in how tax fraud will be policed in the UK. Here are the key takeaways from the session.

1. The Cultural Shift: Valuing the Message, Not Just the Messenger

Historically, the UK has been hesitant to offer financial incentives for whistleblowing, often relying on the notion that coming forward should be its own reward. However, the landscape has changed.+1

Eliza Lockhart, who conducted a comprehensive international review of financial incentive laws, explained that successful programs fundamentally shift the focus from the whistleblower’s motivation to the value of the intelligence provided.

“These programs… prioritize the message, not the messenger… It changes the idea of coming forward from this altruistic act to the provision of an intelligence service.” — Eliza Lockhart +1

Her research shows that financial incentives don’t just generate noise; they drastically increase the volume of actionable intelligence, leading to higher success rates in prosecutions and financial recovery.

2. Inside the New HMRC Scheme: The Nuts and Bolts

Anthony Rodgers, the Operational Lead for the scheme, provided a detailed look at how HMRC is operationalizing this new mandate. The program, formally known as “Rewards for Informants of High Value Tax Fraud,” is designed to target serious non-compliance, including offshore schemes and corporate fraud.

Key Program Specs:

• Threshold: The information must lead directly to the recovery of at least £1.5 million in tax.
• Reward: Eligible informants can receive a taxable reward of between 15% and 30% of the recovered funds.
• Target Audience: The scheme is specifically targeting professionals in finance, law, and business who have access to high-quality intelligence.

Rodgers emphasized that HMRC is looking for specific, documented evidence rather than vague allegations. “Quality information with supporting documentation makes workable cases,” he noted.

3. The “Silver Platter” Standard

A recurring theme throughout the webinar was the importance of how information is presented. Dean Zerbe and Stephen Kohn, both veterans of the U.S. whistleblower system, highlighted that for an informant to be successful, they often need to deliver the case on a “silver platter”.

Dean Zerbe advised that the most successful submissions are often practitioner-led. This means using experienced counsel to organize the facts, explain the legal violations, and ensure the regulator can quickly understand the roadmap of the fraud.+1

“The more you make it easier… the more likely they’re going to want to look at it… and likely that you’re going to get a higher reward.” — Dean Zerbe

4. Navigating Dual Reporting (US & UK)

With global commerce comes global tax evasion. A critical topic discussed was how to handle cases that touch both U.S. and UK jurisdictions. The panel confirmed that there is effective communication between the IRS and HMRC, and practitioners should consider filing in both jurisdictions when applicable, while ensuring transparency with both agencies.+1

Watch the Full Discussion

The launch of the HMRC program represents a breakthrough in international tax enforcement. Whether you are looking to file a claim or simply understand the changing regulatory environment, the insights shared in this webinar are invaluable.