One year on from the introduction of new facilitation of tax evasion offences for corporates, despite repeated warning signs from HMRC that businesses should take the risk of prosecution seriously, some business may not have done enough. Our research shows 55% of the FTSE 100 have not made public statements about their attitude to evasion. HMRC’s Large Business Directorate referred 27 cases of serious tax evasion to HMRC’s criminal teams in 2017/18. HMRC is looking at automatically rating a company high risk if it can’t demonstrate that it has a serious compliance programme. HMRC is chomping at the bit to investigate. Are some corporates being too complacent and where might their current efforts be deficient?