Throughout my career, from law enforcement to advocating for whistleblowers, one truth has remained constant: the government depends on insiders. I often think of the show Unsolved Mysteries, where Robert Stack, clad in a trench coat and surrounded by fog, would say: “For every mystery, there is someone, somewhere, who knows the truth. Perhaps that someone is watching. Perhaps… it’s you.”
He was right. Someone always knows. Whether it’s a whistleblower, a star witness, or a tipster on a hotline, the government relies on these partnerships to solve cases. In turn, it is only right that the government fairly compensates those who take the risk. It takes immense courage to report wrongdoing. Why should anyone shoulder that burden for free?
Unfortunately, that was exactly what our U.K. friends were asking of whistleblowers who had information about fraud involving His Majesty’s Revenue & Customs (HMRC). For years, HMRC had a system in place for whistleblower payments, but it was limited and not rewarding. HMRC often paid out less than £1 million annually across all whistleblowers and other witness payments combined.
Compare that to the IRS Whistleblower program where whistleblowers have helped the United States recover over $7.3 billion in unpaid taxes that otherwise would have remained hidden. By offering a guaranteed percentage of the recovery, typically between 15% and 30%, the U.S. effectively deputized a global network of professionals to help root out tax evasion. In 2024 alone, the IRS collected nearly $475 million thanks to these tips, paying out over $123 million in rewards.
The U.K. Adopts a U.S.-Style Incentive Model
However, the Brits have been paying attention to the success of the IRS program and decided to join the party. The U.K. is now moving away from “token” payments toward a robust, U.S.-style incentive model designed to close the “tax gap,” the multi-billion-pound difference between taxes owed and taxes paid.
The new framework targets high-value, serious non-compliance. HMRC is no longer just looking for small-scale tips. They want original, credible information that uncovers complex schemes intended to defraud the U.K. While the reward scheme requires you to identify yourself to HMRC (anonymous reports are generally ineligible for rewards), the agency is legally bound to treat your disclosure as private and confidential.
The new framework targets high-value, serious non-compliance. HMRC is no longer just looking for small-scale tips; they want original, credible information that uncovers complex schemes.
Key Features
The Focus: High-Value & Complex Non-Compliance
HMRC has moved beyond simple “tax dodging” to focus on systemic, high-value “tax gaps.” This includes sophisticated offshore avoidance schemes involving shell companies and the concealment of assets in non-cooperative jurisdictions. The program specifically prioritizes non-compliance by High-Net-Worth Individuals (HNWIs) and large-scale corporate entities where the tax at stake is significant, often involving cross-border transactions designed to circumvent UK tax residency or permanent establishment rules.
Eligibility: Broad, but Requires Original, Non-public Information
Almost any individual can qualify, including current or former employees, contractors, or even competitors who possess “inside track” knowledge of a scheme. However, while participants in a scheme may sometimes qualify for reduced awards, the program generally excludes those who were the primary “planner or initiator” of the fraudulent activity. This ensures the program rewards those exposing the fraud rather than those who engineered it for profit.
The Rewards: A 15% to 30% Incentive Structure
In a significant shift toward the U.S. model, HMRC now looks to provide substantial financial incentives for cases where the recovery exceeds £1.5 million (excluding interest and penalties). For these high-value disclosures, rewards are increasingly aligned with the 15% to 30% range of the total tax collected. Crucially, for the most significant cases involving multi-million pound recoveries, there is no official upper cap, meaning the payout is limited only by the scale of the tax evasion uncovered. The greater the fraud, the greater the reward.
International Reach: A Global Bounty Program
The program operates with a “long-arm” jurisdictional approach. Knowledge of UK tax violations is a global commodity; therefore, the program is not restricted to UK residents. Individuals based in the United States, Europe, or other financial hubs who have evidence of UK tax evasion, such as those working in international banking, accounting, or global supply chains, can file claims and are eligible for the same percentage-based rewards as domestic whistleblowers.
Why Strengthening Whistleblower Rewards Matters
The UK’s decision to strengthen its reward program is more than a policy update; it is a statement of values. It recognizes that whistleblowers provide a public service that pays for itself many times over. Research suggests that for every pound spent on these programs, the government recovers upwards of twenty times that amount.
When it comes to reporting fraud, incentivized programs are a “win-win.” The government recoups funds it may have never known were even stolen and the whistleblower receives a fair share of the recovery. It is a common-sense investment.
I believe every modern government should follow this lead (Singapore, we’re looking at you). Treating whistleblowers as partners is the single best investment a government can make to ensure a level playing field. It turns the tide by making the risk of being caught far higher than the reward of cheating.
The doors in London are officially open, and the incentives finally match the courage required to walk through them. At Bracker & Marcus, we are excited to help our clients navigate this new international landscape and help solve a mystery.
As Robert Stack would say: “If you or someone you know has information… please call.”