HMRC probes up to £645m in potential tax liabilities for major UK property companies

# What the numbers show

# What "tax under consideration" means The headline number is a HMRC estimate of the maximum additional liability that could arise while an investigation is ongoing. It does not mean the companies under review necessarily owe that tax. The figure represents the scope of the issues HMRC is reviewing before final determinations and case closures.

# Which arm of HMRC is handling these cases These investigations are managed by HMRC's Large Business Directorate, which oversees tax compliance for about 2,000 of the UK's largest businesses, including major listed property groups. The Directorate handles complex corporate and transactional tax matters that typically arise at scale.

# Why the amount has risen BCLP links the rise to an expansion in HMRC's compliance operation. HMRC recruited more than 1,600 compliance officers during 2025–26 and announced plans to add a further 5,500 officers by 2030. The tax authority also reported generating over £50 billion in compliance yield during 2025–26, passing that mark for the first time.

Those staffing and yield changes indicate a larger enforcement footprint and more active reviews of company tax affairs, including property-sector transactions and structures.

# Impact on businesses seeking certainty The data also shows HMRC is offering less pre-transaction certainty. In 2025–26 HMRC rejected 41% of requests for confirmation of tax treatment — the highest proportion in five years. The rejection rate for corporation tax requests was 63%, more than double the previous typical range of 25%–30%.

For companies considering large or complex deals, a higher rejection rate for advance confirmations increases uncertainty. Firms that previously relied on formal confirmation to shape transaction structures may face greater enforcement risk or have to factor potential challenges into deal pricing and tax provisions.

# Practical implications for property companies

• Expect more active HMRC queries and investigations into transaction structures, disposals, and tax positions.
• Increased uncertainty over pre-transaction rulings means companies may need to allow for potential additional tax liabilities when assessing deals or provisioning in accounts.
• Larger compliance teams at HMRC suggest investigations may become more numerous and potentially more detailed, increasing the administrative burden on corporate tax teams and their advisers.

# Bottom line The £645m figure signals heightened HMRC activity in the property sector rather than confirmed tax debts. Companies in the sector should be aware of increased enforcement capacity, a lower likelihood of receiving pre-transaction confirmation, and the potential need to reassess tax risk handling for large transactions.