HMRC’s Wealthy Taxpayer Letters: What They Mean for UK and International Investors, By Atef Elmarakby | GOOD LAW INTL | 27 October 2026
GOOD LAW INTL® | PRIVATE CLIENT • TAX & WEALTH PLANNING • Legal Insight | October 2026
HM Revenue & Customs (HMRC) has been writing to wealthy individuals to introduce a dedicated Customer Compliance Manager and seek a clearer understanding of their financial affairs.
The letters have attracted attention following a Sunday times report on HMRC’s requests for information about the assets and financial arrangements of wealthy taxpayers. For British nationals and international investors with UK connections, the development is a reminder of the importance of reviewing how their wealth is held, reported and taxed.
Receiving a letter does not necessarily mean that HMRC believes the recipient has done anything wrong. It does, however, indicate that HMRC wants a better understanding of the individual’s affairs and may wish to discuss matters that could affect their UK tax position.
What does the HMRC letter say?
A copy of a letter circulating online introduces the recipient to an HMRC Customer Compliance Manager, or CCM, from its Wealthy Team. It explains that the manager’s role includes understanding the recipient’s assets, investments, business interests and wider financial arrangements.
The letter also refers to information HMRC receives from the UK and overseas and indicates that the manager may review businesses in which the recipient is a shareholder.
HMRC’s Wealthy Team and its use of CCMs are established parts of its compliance work. HMRC says CCMs are assigned to individuals whose affairs involve particularly high levels of complexity or opportunities for non-compliance. They develop an understanding of the individual’s finances and review returns alongside information from other sources.
The authenticity of any particular letter should nevertheless be checked independently with HMRC, especially where the recipient has seen only an image or a redacted copy.
Why is HMRC sending these letters?
The letters form part of HMRC’s broader approach to understanding and managing tax compliance among wealthy individuals.
In September 2026, the Treasury confirmed to Parliament that HMRC had allocated a CCM to every billionaire with a UK tax footprint over the summer. It also explained that CCMs are allocated according to wealth, complexity and risk.
HMRC’s interest is not limited to billionaires. Its published guidance describes an individual as “wealthy” for its compliance purposes if they have had an income of £200,000 or more, or assets of £2 million or more, in any of the previous three years. That definition does not mean that everyone meeting either threshold will receive a letter or be assigned a dedicated manager. www.gov.uk
For many individuals, the relevant complexity may arise from a combination of UK and overseas property, business interests, investments, trusts, family structures and changes in residence.
Does receiving a letter mean you are under investigation?
Not necessarily. An introductory letter assigning a CCM is not, by itself, an accusation of tax evasion or proof that a formal enquiry has been opened.
That said, HMRC may subsequently ask questions, review tax returns or open a formal compliance check. The exact position depends on the complete correspondence, including any accompanying documents.
A recipient should therefore read the letter carefully, note any deadlines and seek advice before responding. It is also sensible to check whether a copy has been sent to their accountant or authorised tax agent.
What could HMRC ask about?
Depending on the individual’s circumstances and UK tax position, discussions may cover:
- UK and overseas property;
- shares and interests in private companies;
- investment portfolios, bank accounts and other financial assets;
- income, dividends, gains and distributions;
- trusts, partnerships and family office arrangements;
- gifts, inheritances and transfers between family members; and
- residence history and connections with other countries.
The fact that HMRC asks about an asset does not automatically mean the asset is subject to UK tax. The answer depends on the nature of the asset, the taxpayer’s circumstances and the relevant tax rules.
What does this mean for wealthy British nationals?
For British nationals living in the UK, the letter may prompt a review of both UK and overseas income, gains and financial structures.
UK tax residents are generally liable to UK tax on worldwide income and gains, subject to applicable reliefs and exceptions. A British national who owns a foreign company, receives overseas rental income or holds investments abroad should therefore consider whether their UK reporting is accurate and complete.
British nationality alone does not determine UK tax residence. A British national living abroad may be non-UK resident, depending on the statutory residence rules and the facts for the relevant tax year. Conversely, time spent in the UK, homes, family connections and other factors may affect the residence assessment.
For example, a British national living in Dubai who owns London rental properties should review both their UK residence position and whether UK rental income and any property disposals have been properly reported.
What does this mean for overseas nationals with UK assets?
An overseas national may have UK tax obligations even if they live outside the UK and have never held a British passport.
For a non-UK resident, the focus will often be on UK-source income and UK assets. Relevant matters may include:
- rental income from UK property;
- income arising from UK employment or business activities;
- gains on the disposal of UK land or property;
- certain indirect disposals involving UK property-rich entities; and
- inheritance tax exposure relating to UK-situated assets.
For example, an Egyptian national living in Cairo who owns a London investment property may need to report UK rental income and comply with UK rules when the property is sold. A double taxation agreement may be relevant and should be considered alongside the domestic rules of both countries.
Non-residents must generally report disposals of UK property or land even where there is no tax to pay or a loss arises. For individuals, the usual reporting and payment deadline is 60 days from completion, subject to the applicable rules.
Holding a UK property through a company or another structure can change the analysis, but it does not automatically remove UK tax or reporting obligations. The position depends on the structure and the transaction.
What about inheritance tax and overseas assets?
Inheritance tax is a separate consideration from income tax and capital gains tax.
Since 6 April 2025, the UK has used a long-term residence-based test in place of the previous domicile-based approach for these purposes. A person who is a long-term UK resident may be within the scope of UK inheritance tax on overseas assets as well as UK assets, subject to the detailed rules, reliefs and any applicable treaty provisions.
A person may remain a long-term UK resident for inheritance tax purposes for a period after leaving the UK. The length of that period depends on their residence history and the applicable transitional rules.
For internationally mobile families, this makes it particularly important to review estate planning, wills, trusts and the ownership of UK and overseas assets together.
Must you attend a meeting or provide a complete list of assets?
An introductory letter should be distinguished from a formal statutory information notice.
An invitation to meet or an informal request for information is generally voluntary. The visible page of the letter circulating online does not itself establish an obligation to provide a complete asset list. The full letter should be reviewed before a decision is made.
HMRC does, however, have statutory powers to require information or documents in appropriate circumstances. Under Schedule 36 to the Finance Act 2008, a taxpayer notice may require information or documents that are reasonably required to check the taxpayer’s tax position. There are safeguards and, in some circumstances, appeal rights; those rights are subject to exceptions, including for certain statutory records and tribunal-approved notices.
The practical approach is to understand what HMRC is asking for, why it is relevant and whether the request is informal or compulsory before responding.
Does the letter mean the UK is introducing an exit tax?
There has been speculation that HMRC’s interest in the assets of wealthy individuals could be connected to a future exit tax. At present, the letter itself does not announce such a tax, and speculation should not be treated as confirmation of government policy.
Individuals considering leaving the UK should nevertheless obtain advice on the existing rules. These can include residence, temporary non-residence, capital gains and the continuing inheritance tax consequences of long-term UK residence.
What should you do if you receive a letter?
We recommend taking the following steps:
- Verify the letter independently. Contact HMRC using details obtained directly from GOV.UK, rather than relying solely on contact information in an unexpected letter.
- Provide the complete correspondence to your advisers. Include all pages, attachments, references and deadlines.
- Identify the nature of the request. Establish whether it is an introduction, an invitation to discuss matters, a formal enquiry or a statutory information notice.
- Review your UK tax position. Consider your residence history, returns, income, gains and relevant assets and structures.
- Coordinate your response. Your legal and tax advisers can help determine what information is relevant and how best to communicate with HMRC.
- Address any identified errors promptly. If a review identifies an omission or inaccuracy, obtain advice on the appropriate steps and disclosure route.
How GOOD LAW INTL can assist
GOOD LAW INTL advises UK and international clients on legal matters involving UK assets, business interests and cross-border structures. We can work alongside tax advisers and accountants to help clients review their circumstances, understand HMRC correspondence and coordinate an appropriate response.
If you have received an HMRC letter or would like to review your UK assets and wider estate planning, please contact GOOD LAW INTL for an initial discussion.
This article provides general information as at 27 October 2026 and is not a substitute for advice on individual circumstances.
