Foreign tax authorities are intensifying their scrutiny of UK taxpayers, with targeted requests for information from HM Revenue & Customs reaching their highest level in seven years as international efforts to tackle offshore tax avoidance gather pace.
Data obtained under the Freedom of Information Act by Price Bailey, the chartered accountants, shows that HMRC received 1,772 targeted information requests from foreign tax authorities in 2025.
That was the highest annual figure since 2019 and represented a 20 per cent increase from 2022, the first fully post-pandemic year, when HMRC received 1,472 requests.
The trend is moving in the opposite direction at HMRC. Requests sent by the UK tax authority to its overseas counterparts fell by 39 per cent between 2022 and 2025, from 697 to 424.
The divergence highlights a changing phase in the international campaign against offshore tax non-compliance.
HMRC moved relatively early to exploit international information-sharing frameworks, including the Common Reporting Standard and the US Foreign Account Tax Compliance Act, or FATCA. Price Bailey said this allowed the UK to address many of the more straightforward offshore cases at an earlier stage.
Other tax authorities are now making greater use of the same global transparency infrastructure, increasingly turning automatically exchanged data into targeted investigations.
Although large quantities of financial information are exchanged automatically between tax authorities, specific requests remain important when officials require detailed records, clarification or information that is not contained in standard reporting.
The rise in targeted requests suggests overseas authorities are increasingly using information already received through automatic exchanges to identify potential discrepancies before seeking additional evidence from HMRC.
Andrew Park, tax investigations partner at Price Bailey, said the increase represented a significant change in the international enforcement environment.
“Foreign tax authorities are stepping up their offshore enforcement, and we are now seeing more targeted information requests about UK taxpayers than at any point in the last seven years.”
The approach taken by foreign authorities can also differ materially from HMRC’s domestic enforcement strategy.
“HMRC often uses nudge-letter campaigns or amnesties to give taxpayers the chance to put things right at minimal cost. Many foreign tax authorities take a more adversarial approach and impose tougher penalties or more readily criminally prosecute for non-compliance,” Park said.
The information being sought can extend well beyond conventional bank-account records.
Price Bailey said foreign authorities were increasingly requesting historic information on transactions including overseas property sales, cryptocurrency trading on international exchanges and income generated through digital platforms.
Automatic reporting systems provide tax authorities with information in prescribed formats, but bilateral tax information exchange agreements and information-sharing provisions contained in double-tax treaties can allow authorities to seek much broader records from HMRC.
The development creates a more complex environment for internationally mobile taxpayers, particularly those with assets, investments or sources of income spread across multiple jurisdictions.
Park warned that taxpayers should not assume that information exchanged between tax authorities is limited to the financial data most commonly associated with international transparency rules.
“People associate the exchange of information between tax authorities as meaning bank account data and little else. However, tax authorities often share more information than that and one must assume that any information that could be in the hands of one tax authority could also be shared with international counterparts.”
Artificial intelligence is also changing the capacity of tax authorities to analyse large volumes of information.
“AI systems can rapidly cross-reference data from all sources, compare them with tax returns and identify discrepancies. That is a very different environment from the one taxpayers were dealing with even a decade ago,” Park said.
The decline in HMRC’s outbound requests has a different explanation, according to Price Bailey. The firm said it partly reflected the tax authority’s earlier success in addressing straightforward offshore non-compliance.
But it also warned that changes in Britain’s tax environment could eventually affect the amount of international enforcement activity generated by HMRC.
Price Bailey said the increasing tax burden on high earners could encourage some internationally connected wealthy individuals to relocate, reducing the number of UK residents with overseas affairs requiring investigation.
“We have already seen many high-profile internationally mobile individuals relocate — Chris Rokos is one recent example — and others may reassess their position as the tax landscape evolves,” Park said.
“If fewer globally connected people remain UK-resident, HMRC will naturally have fewer overseas matters to enquire about.”
The figures point to a potentially important shift in the international tax landscape. As global information-sharing systems mature, tax authorities are moving beyond simply collecting data and increasingly using it to identify specific taxpayers and transactions for further investigation.
For UK taxpayers with international financial interests, the era in which offshore activity could remain largely detached from domestic tax scrutiny is becoming increasingly difficult to sustain.
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