The top five key developments in the field of tax investigations during 2010 have been: the implementation of the new penalty regime; the confident use by HMRC of their new information powers, including international dimensions; project investigations and use of special ‘deals’ for classes of taxpayer; development of HMRC intelligence services and risk assessment; and the new approach to investigations of extractive fraud, tax evasion and tax avoidance. Looking forward to 2011 we should expect to see the impact of the £900 million funds to be released under the Spending Review by way of an increase in prosecutions of tax evaders and complicit advisers. We will also see the impact of the naming and shaming provisions on tax defaulters.