Finance (No. 2) Bill

Kirsty Blackman Excerpts

Wednesday 11th March 2026 Commons Chamber

[Gareth Snell (Stoke-on-Trent Central) (Lab/Co-op)]

I will speak to the two new clauses that stand solely in my name, which relate to the impact of the changes to the remote gaming and remote betting duties. I do not intend to relitigate the rights and wrongs of those changes; we have had a number of debates on that subject in this Chamber and in Westminster Hall, and the determination has been settled by Treasury. However, I do think it is important that we consider what I believe are the genuinely unintended consequences of the changes that the Treasury will introduce and how best to mitigate them. To mitigate them, though, we need to understand them, so new clause 8 simply seeks to get an independent assessment of the changes to the remote betting and remote gaming duties on the black market.

I am sure that those of us who have participated in debates around gaming and gambling will accept that there are challenges that we need to address with problem gambling, but that requires people to participate in the regulated sector, where help and support is available for those who find themselves getting into trouble. The more people we push into the black market—where there is no support, no GamCare, no lock-out system—the more people are at risk of harmful activity and being preyed upon by predatory organisations and companies that are outside the UK, do not pay taxes here and are simply not worried about the participants.

The independent study done by EY for the Betting and Gaming Council found that there is a potential for £6 billion-worth of stakes to be diverted into the black market as a result of this change. That is £6 billion of stakes that were going to be made somewhere, but will now go into the black market and will therefore not be subject to any taxation, including any form of potential corporation tax if they are staked outside the UK with one of the companies headquartered elsewhere, or to the remote gaming duty. That is a 140% increase on the potential stakes going into the black market.

It also means thousands and thousands of people—our constituents—who will find themselves in an unregulated part of the gambling and gaming economy, where there is absolutely no help and support for them. The people who run those sites have no interest in the welfare of those individuals whatsoever; they simply want to try to maximise their profits. Every single one of us is no more than two clicks away from an unregulated gaming or gambling site, and we should be open and acknowledge the fact that that money often funds questionable activities overseas, including organised crime and, in some cases, terrorism.

I recognise that the Treasury has, as part of broader changes to the betting and gaming regulations, identified £26 million for the Gambling Commission to try to mitigate some of the worst aspects of those activities, but we simply do not know what impact that will have; the assessment has simply not been done by the Government to determine whether that £26 million is enough. Frankly, every penny that could be spent on helping people in this country to avoid damaging gaming and gambling, and to enjoy regulated gaming and gambling, should be spent.

[Kirsty Blackman (Aberdeen North) (SNP)]

Have the Government given the hon. Member any idea of when a post-implementation review of this legislation might be done, and therefore when the Treasury can say how much tax has been gathered and how much has been lost as a result of these changes?

[Gareth Snell]

That is an incredibly fair question. The Treasury has been unable to give me an answer, but I hope that the Minister will be able to when he sums up the debate. Regardless of one’s views on gambling, we must ensure that the implementation of new levies does not drive people into the black market, because that is where they are most exposed to risk. If people are to participate in gaming and betting, I would much rather they did so in UK-based, regulated services, where they can get help and support if needed, and where the taxes they pay can go towards funding our public services. It is a fair point, and one on which I hope the Minister will be able to provide an answer.

I wonder whether the Minister could also give some thought to the following point. This taxation has been hypothecated, in the narrative, as being directly to fund the Government’s welcome lifting of the two-child benefit cap, but in reality that is not how taxation works in this country—we do not hypothecate specific taxation lines to pay for specific social policies; instead, the money goes into the Treasury pot, and the Treasury, in its infinite wisdom and benevolence, hands it out to other Departments, which then make their spending commitments.

Now, the Government’s own OBR forecast suggests that, given the behavioural changes expected to take place as a result of the differential rates between the regulated and unregulated sectors, and given the people who will pay tax, the yield from this tax will potentially be down by a third by 2029-30—that means somewhere in the region of £300 million will be lost. If we are making this direct comparison, saying that the levy is needed to fund the welcome change in the two-child benefit cap, can the Minister set out where the additional funding will come from in 2029-30, if the reduction resulting from behavioural change takes place?

Even if the Government are unable to support my new clause 8 tonight, a proper impact assessment would at least allow a better understanding of future challenges relating to the behaviour of consumers and the impact on tax yield.

My new clause 9 seeks a similar impact assessment, but in relation to our friends in Gibraltar. The Minister will be acutely aware that the gaming and gambling sector is a huge part of Gibraltar’s economy—30% of its GDP comes from the sector, and it employs some 3,500 people. The gambling and gaming companies that have a footprint in Gibraltar pay Gibraltar corporation tax as well as any levies paid in the UK. However, because it is a top-line tax, rather than a bottom-line tax, any impact on the profitability of companies based in Gibraltar, or any behavioural changes in the stakes put through those companies, will have an immediate and direct impact on Gibraltar’s revenues.

One third of Gibraltar’s tax receipts come from the sector, so anything we do in this place that has an impact on the sector there—I entirely accept that this is not an intended consequence of the decision—would leave a huge hole in its economy, and that will have to be filled. We are talking about potentially tens of millions of pounds, if not hundreds of millions. Gibraltar is, of course, one of the family of nations that make up Britain, and we have to ensure that, given its strategic importance because of our defence work, we do nothing that makes it less safe as a result of tax changes here.

Of course, the Government of Gibraltar are currently putting through their Parliament the changes to the EU-Gibraltar treaty, which will help with the flow of the gaming sector’s workforce, given the cross-border nature of the workforce. However, Nigel Feetham—the Member of the Gibraltar Parliament who holds the justice, trade and industry brief—has said that what Gibraltar really needs is stability, and not to have “avoidable” decisions from the UK. I know that the Government will resist my new clause, but I ask the Minister to lay out what communications and active engagement he and the Treasury have had with our friends in Gibraltar.

Gibraltar is of strategic importance to us and part of the family of nations that makes up who we are, and decisions that we take in this Finance Bill are having a huge impact on its economy and its ability to fund its public services, which contribute to our overall national defence. While Gibraltar is embedding the new treaty changes, it is important that it has some certainty about its revenue stream.

The media are reporting that the Gibraltarian Government are looking at rapid diversification of their economy to make up the difference, but realistically we do not know what the impact will be on our economy, and they certainly do not know what the impact will be on theirs. The Minister will be acutely aware that as Gibraltar is dependent for 30% of its tax intake from one sector, even a small change here in the UK could have a hugely detrimental impact over there. I hope that he will address the stability that the Gibraltar Parliament has been asking for, and for which Nigel Feetham has rightly been asking in his engagements with the Treasury.

Finally, I had not intended to do so, but I will touch on new clause 10 tabled by the Opposition about CBAM. I have often talked in this place about the importance of our manufacturing industries, and not least the ceramics industry, which falls outside the current proposals for CBAM but will be subject to the emissions trading scheme. There is a perversity about the emissions trading scheme and CBAM in that if we get it wrong, we will just drive up prices for consumers and for producers, while others are importing into our country ceramics produced using cheap Russian gas, which means that their price point is much below what we can produce them here. It also has the distorting effect that our exports become more expensive when they hit the CBAM—particularly for Europe.

Therefore, while we are at a point of global turmoil and gas prices are increasing hugely overnight—the price per therm was 74p last week; it is now somewhere around 160p—there is some work to be done by the Treasury. I asked the Chancellor about that in her statement on Monday; unfortunately, she missed the point about gas-intensive industry and went straight to electric-intensive industry, which is different. When the Government look at how we do CBAM and where we will have free allowances for the ETS, will the Minister bear in mind those small sectors such as ceramics that are crucial to our foundational manufacturing? I am talking not about the tiles, tableware and giftware that I talk about so often, but about the advanced ceramics that we need in this country, which are dependent on a gas price that works and being able to trade across the European border without huge external tariffs being placed on them because of carbon leakage.

Nuclear submarine air filtration systems are ceramic, and the rotor blades that go on small modular reactors made in Derby will require a ceramic powder coating for them to be utilised that will have to cross many borders. There is the potential that we price out British manufacturers as a result of the CBAM and the ETS if we do not have some of those lifelong allowances and we do not think about the interplay of components that travel over borders. Therefore, while I had not intended to speak about the Opposition’s new clause 10, the hon. Member for North West Norfolk (James Wild) made a valid point in terms of ceramics. Even if the Minister will not take the new clause forward—obviously we will not support it, because it is not a Government amendment—the hon. Gentleman’s point is worthy of consideration in a different form.

--- Later in debate ---

[Alex Ballinger (Halesowen) (Lab)]

Before I start, I should declare that I am co-chair of the all-party parliamentary group on gambling reform. I want to talk about new clauses 8 and 9, which my hon. Friend the Member for Stoke-on-Trent Central (Gareth Snell) spoke to earlier. They are thoughtful, well-meaning new clauses that address real concerns. I want to add a bit of context, and set out what the evidence shows about the black market and the situation in Gibraltar.

Industries associated with harm often use the black market as an excuse to avoid regulation or additional taxation. When I was on the Finance Bill Committee last year, we received a lot of correspondence from the tobacco industry, in which it made the same sort of claim. We were seeking to increase taxes—the shadow Minister, the hon. Member for North West Norfolk (James Wild), might remember the debate—and the tobacco industry was using the black market as an excuse for why that should not happen. In the gambling sector, the threat of the black market is overblown. The regulated market is dominant, and in recent years there have been lots of taxation changes that have not increased the size of the black market. I will give two examples.

When we changed from taxing turnover to taxing profit in 2001, the black market was highlighted as a risk, but there were no real changes. Again, when we introduced the point-of-consumption tax in 2014, there was no surge in unregulated or black market gambling. Indeed, a 2021 Gambling Commission study found that only a very small proportion of UK gamblers ever used unlicensed sites, and they did so mostly by accident. As my hon. Friend the Member for Stoke-on-Trent Central accurately pointed out, people who are banned from regulated sites sometimes turn to the unregulated sector, and that truly is a problem.

Focusing on the black market risks diverting attention away from the significant and better-evidenced harms in the regulated sector. Those harms are most widespread in the areas in which we are seeking to increase taxes—we have discussed that, so I will not go into it too much. However, it is important that we tackle the black market, so I welcome the illegal gambling taskforce that has been introduced, as well as the additional £26 million for the Gambling Commission to address those issues. We should not buy into the narrative that risks from the black market should stop us making changes to keep people safe from the most harmful forms of gambling.

If the tax changes are as economically damaging for Gibraltar as has been claimed, we need to consider how they work in other jurisdictions. The same gambling organisations often operate in other countries with much higher tax rates than the UK, and they manage to survive profitably in those sectors. I think that we should take that into account when considering new clause 9 and the impact on Gibraltar.

[Kirsty Blackman]

You would not believe, Madam Deputy Speaker, how far beyond delighted I was when I discovered that I would be stepping in for a colleague on the Finance Bill. I am sure that the House is similarly ecstatic to hear me speak on the Bill. I did a significant number of Finance Bills in my first few years in this place, and I have missed it. I have also missed the former Member for Amber Valley, Nigel Mills, who used to make a speech from the Government Back Benches about something that nobody else had even considered or knew existed. The hon. Member for Stoke-on-Trent Central (Gareth Snell) is very kindly stepping into his shoes and raising issues relating to gambling tax, which, to be fair, are important. He is asking very important questions, as Nigel Mills used to, about a fairly niche subject. In the light of the hon. Member’s comments about gambling taxation and the black market, it would be great if the Treasury provided updates on how the tax has worked.

In fact, I think the Treasury should generally provide more updates on every tax measure that it implements. If the Treasury says that a tax measure will raise £30 million, it would be helpful for the MPs who sat on the Finance Bill to know whether it did in fact raise £30 million, or if it raised £50 million or £10 million. Then, we could make better decisions about future tax changes, because we would have a better idea of whether they would achieve the Government’s aims. Successive Governments have been particularly bad at undertaking post-implementation reviews, particularly of tax measures. It would be really handy to see that information more regularly, so that we can make better-informed decisions.

Let me touch on the transparency issues that have been mentioned. Earlier, I raised my concerns about the fact that additional Ways and Means motions were added at this point. I also raised the fact that we do not have oral evidence sessions during the passage of the Finance Bill. I continue to make the case that that could be done after Committee of the whole House. Usually the more technical aspects of Finance Bills are considered in a Public Bill Committee in a Committee Room, rather than in a Committee of the whole House in the Chamber.

The Minister said that some Government amendments had been tabled following stakeholder feedback—particularly through written evidence—to clarify the intention of the legislation. The Government had intended to do something, and stakeholders said, “We don’t really understand this; it’s not clear enough. Could you clarify it?”. If the Government had held oral evidence sessions, they may have been able to make those changes in Committee, rather than on Report. I urge them, and any future Government, to consider holding oral evidence sessions. Anyone who has been on a Bill Committee in which there are oral evidence sessions will understand their great value, and we refer back to them so many times throughout the course of a Committee. There is nothing quite like being able to ask an expert questions, rather than just looking at the written evidence, which is helpful, but it is not the same. We do not remember written evidence in the same way, and we do not have the same ability to probe it.

I want to touch on the four amendments that may be put to a vote. The SNP and I are happy to support new clause 4, tabled by the hon. Member for Walthamstow (Ms Creasy). I was thinking about the history of some “get rich quick” schemes. We had Ponzi schemes and pyramid schemes. The new thing—the Ponzi scheme of the day—is the scheme that says, “This is foolproof. This is failsafe. You are going to make loads of money doing this,” but it is actually unregulated. The new clause would be incredibly helpful. I would have preferred the new clause to say “user-to-user services” instead of “social media”, so that it would cover all the stuff in the Online Safety Act 2023. That covers things that we may not classically define as social media. For example, if somebody gave really terrible tax advice on a money-saving expert forum, would that be included in the definition of social media? Social media is not 100% defined, which is why I would have preferred a different term. However, the new clause is sufficient to cover the majority of people.

[Ms Creasy]

I feel the need to stand up for Martin Lewis, because he is one of the good guys when it comes to advice, and those forums are policed very well. The problem is people exploiting the fact that social media companies also have a vested interest in generating content that goes viral. They are the sole publishers of these videos—they make money from them—that tell people outlandish things that they can do with their taxes. I think we all agree that it is worth looking at the Money Saving Expert forum. I peruse it at length myself, much to the detriment of being able to make decisions.

[Kirsty Blackman]

It is absolutely worth looking at that forum, but as the hon. Member said in relation to the new clause, people who are promoting schemes with no expectation that they will actually work should not be doing it on money-saving expert forums, or anywhere else. I agree that Martin Lewis has been very clear that he does not give advice online, and that people who, for example, say, “This is a Martin Lewis tip” are lying. It is worth highlighting that the way in which he has chosen to put forward tax advice or information is totally different to the way chosen by the financial influencers referred to in new clause 4. As I said, I am more than happy to support it; I would have just liked it to be wider.

We are happy to support new clause 11 on the uprating of agricultural relief, tabled by the Liberal Democrats. If the new clause and the uprating is not to be implemented, it would be incredibly useful to see the Government’s rationale for why they have chosen not to do annual uprating in a way that would be standard for the majority of other reliefs. What is the logic for that? As I was not on the Bill Committee, I am not as across this part of the Bill as I perhaps should be, so I am not clear what mechanism is in place to uprate the relief. Is it done under the negative or affirmative statutory instrument procedure? Will the House actually see a statutory instrument, or is a delegated authority given to the Minister? It would be helpful to have an idea of what the mechanism is, and whether, if inflation continues at the current rate or goes up again, the Government are likely to put in place an increase to ensure that agricultural relief continues to wash its face—to provide the relief it is supposed to.

[Ben Maguire (North Cornwall) (LD)]

I wholeheartedly endorse what the hon. Member is saying in support of new clause 11 tabled by the Liberal Democrats. Lots of my farmers in North Cornwall are constantly telling me that they are pleased with the Government’s decision to change course on the family farm tax, but it is essential that they keep rising prices in mind, exactly as the hon. Member says.

[Kirsty Blackman]

I absolutely agree. With the uncertainty in the middle east just now, we are seeing an increase in fuel prices, which will heavily impact farmers, and fertiliser prices. Since Russia invaded Ukraine, fertiliser prices have gone through the roof and it has been difficult to get hold of at all, so farmers need support. We have always relied on growing food, but in this ever more uncertain world we really need to rely on growing our own food. This Government—and all Governments—need to consider whether we want to be self-sufficient, or anywhere near self-sufficient, in food, or we are happy to see our farms dismantled to create ever-larger, Australian-style sheep farms, with thousands of sheep on them and nothing else. We need to consider what future there is for our farmers and ensure that we are backing that future.

--- Later in debate ---

[Robbie Moore]

I endorse what the hon. Member says. I cannot get my head around the fact that there are so many family businesses, beyond the agricultural sector, that will be impacted by the business property relief threshold at £2.5 million. They include manufacturing businesses and those in the hospitality sector, and many of them will be in the constituencies of Labour MPs. I cannot understand why, during the course of this Bill, many Labour MPs have been silent on the issue of business property relief, and why they are not standing up for family businesses. I endorse what the hon. Member says about fire sales happening as a result of an increased inheritance tax liability.

[Kirsty Blackman]

Given that we have a Labour Government who care about workers’ rights, the family businesses that I have visited have a strong worker involvement. The people who work there are cared for and looked after because it is a family business, and one would think that the Labour party would want to support more of those rather than encouraging people to get out of that place. I agree with the hon. Gentleman and I have big concerns on the matter.

As my hon. Friend the Member for Aberdeenshire North and Moray East (Seamus Logan) is currently leading a debate in Westminster Hall, he is unable to speak to his amendments himself, so I would like to talk about the reasons that he has tabled them. He has tabled a number of amendments in relation to APR and the anti-forestalling clauses. We are pleased that the threshold for APR was raised—that is welcome—but we are concerned about the backdating and the fact that the changes relate to things from 2024 onwards, rather than from April 2026 onwards. My hon. Friend’s amendments relate specifically to those anti-forestalling issues and ask for changes to be made, so that there is no backdating on the transactions. A number of agricultural organisations and farmers in his constituency have asked for those changes to be made, which is why he has put forward those amendments. The Government have raised the threshold, which is welcome, but if they continue to push forward with this measure, that will not be enough. Either cancelling it completely, as suggested by the Conservatives, or looking at the date would be incredibly helpful in ensuring that it is not backdated or retrospective, so that people do not lose relief on changes announced or made previous to the Budget.

My hon. Friend also tabled amendments in relation to whisky duty, which would take out clause 86. Over the last three years, we have seen an 18% hike in whisky duty. The figures show that there will be a £600 million downgrade in receipts as a result of continuing to increase this tax. Increasing the tax will reduce receipts, which will result in jobs in Scotland being put at risk, and the Government getting less money. I do not understand the logic of continuing to push ahead with raising whisky duty.

We really want the Government to think again. [Interruption.] To be fair, the 18% hike over three years was down to both Labour and the Conservatives, so I am afraid that the Conservatives do not have a huge amount of high ground. This issue has happened under both parties, but we will continue to fight on behalf of Scottish whisky producers. The tax on spirits needs to be looked at seriously, because this is an important part of the Scottish economy; it provides jobs in rural areas where depopulation is a big issue. We need these companies to continue, but if the Government continue to raise tax and hike the tax rates, we will see those jobs dropping off.

Amendment 140 has not been selected, but it is the only amendment put forward by our merry band of Reform colleagues, although they signed some other amendments. If anyone looks at that amendment, which we would presume is Reform’s key priority, given that that is the only amendment it has put forward, they will see that it would remove clause 88, which increases cigar duty. The main priority of Reform in the entire Finance Bill is that the Government should not be allowed to increase duty on cigars. That says a huge amount about the priorities of those who sit on the Reform Benches for the general people. To be fair, no Reform Members are here.

[Lincoln Jopp (Spelthorne) (Con)]

They’ve gone up in smoke! [Laughter.]

[Kirsty Blackman]

That was truly brilliant.

With all the craziness that we face in the world and all the issues faced by farmers, businesses and those who are badly advised by people making up tax advice on the internet, if the key priority of Reform is, “Let’s not increase the price of cigars”, it has got something wrong in the way that it deals with things.

I have laid out exactly how the SNP will deal with each of the votes that will take place, including our abstention on the income tax thresholds, because they do not apply in Scotland. I am very clear that we continue to have major concerns about APR and BPR.

I want the Government to think again about whisky duty and the level of transparency and scrutiny provided throughout the course of the Bill. This is not the first time I have asked for that, and Members are probably sick of me asking for oral evidence sessions to be included in the Bill, but I will keep asking until that happens. If the Government want to stop me having this conversation, just make it happen, and we will be completely grand.

[Phil Brickell (Bolton West) (Lab)]

I will speak to new clause 4 in particular, and to the wider issue of tax dodging and enforcement in this country. I make these remarks as chair of the all-party parliamentary group on anti-corruption and responsible tax.

I begin by congratulating the Government on the action they have already taken to tackle tax avoidance and evasion. The measures brought forward by the Chancellor and the Treasury team to strengthen HMRC’s powers, invest in enforcement and crack down on abusive tax schemes represent an important step in restoring fairness to the system. They have sent a clear signal that in Britain, the rules should be the same for everyone. The same rules should apply to the multinational company and the market trader, to the billionaire and the builder, and to those with the most expensive accountants and those who simply pay what they owe. More broadly, I also welcome the Government’s wider economic plan, which, despite global headwinds outside the Chancellor’s gift, is beginning to restore stability after years of uncertainty and drift. After 14 years in which economic instability and mortgage-spiking kamikaze Budgets became the norm, restoring stability is no small achievement. It is the foundation on which everything else must be built—investment, growth and confidence that the system is working in the interests of ordinary working people.

I turn to new clause 4. As a financial crime compliance officer in a previous life, in which role I spent many years dealing with the practical realities of financial crime controls, anti-money laundering systems and tax compliance, I recognise the principle that my hon. Friend the Member for Walthamstow (Ms Creasy) is pursuing—that of cracking down on the enablers of crackpot tax avoidance schemes. We have all seen the rise of so-called online finfluencers promoting dubious arrangements. These schemes are dressed up as clever financial advice, but in reality, they promise something that should always ring alarm bells: something for nothing. I make no judgment on the merits of my hon. Friend’s new clause, and I would welcome further discussion about it with her after today’s debate. My sincere hope is that HMRC is already fully alert to the risk posed by these schemes, and is monitoring the promotion of them closely. I hope the Minister will be able to comment on that when he winds up.

However, my hon. Friend the Member for Walthamstow has, on a fundamental issue in this country, hit the nail on the head. In many ways, aggressive tax avoidance and tax evasion have become decriminalised, not through any change in the law but through something far more corrosive—a lack of enforcement. Laws can exist on the statute book, offences can be created and powers can be granted, but if those powers are not used and those laws are not enforced—if those who break the rules rarely face consequences—the signal that is sent is unmistakeable.

I am afraid to say that much of this decline occurred on the watch of the Conservative party. For 14 long years, we saw enforcement weaken, complexity increase, and a culture emerge in which some individuals and firms appeared to believe that paying tax was optional so long as they could afford sufficiently inventive advice. At the same time, the Conservatives drove the tax burden to the highest level in 80 years while turning a blind eye to those who simply refused to pay it. In response to an intervention earlier from the hon. Member for Bridgwater (Sir Ashley Fox), who unfortunately is not in his place, it was the Conservative Government in 2023 who scrapped the Office of Tax Simplification. Now, the official Opposition have the audacity to talk about making £47 billion of cuts, which is the equivalent of firing every police officer in Britain twice over. It is simply not credible.

Members may recall my speech on 27 November last year, during the Budget debate. For those who do not, in my remarks I referenced one of the more surreal examples of tax avoidance that has surfaced in recent years, which is the elaborate mollusc-based wheezes used to avoid business rates. These are schemes so convoluted that they led one high-profile individual to acquire more knowledge than anyone should ever reasonably possess about snail fornication, snail gestation, snail feed and—rather disturbingly—snail cannibalism. You really could not make it up: slimy advisers, snail farms and shell companies, all deployed in the service of dodging a lawful tax bill. It sounds absurd, and in many ways it is, but it also illustrates something deeper and more troubling. The creativity deployed in designing these schemes—the ingenuity, complexity and sheer effort involved—is often directed not towards creating wealth or innovation, but towards avoiding a basic civic responsibility. That is why I welcome clause 156, which prohibits the promotion of tax avoidance arrangements, with civil penalties and criminal offences built into the Bill to tackle the unlawful promotion of such initiatives.

On enforcement, the Bureau of Investigative Journalism has highlighted just how far things have fallen in recent years. Prosecutions against enablers of tax evasion dropped by around 75% between 2018 and 2024, and HMRC has not fined a single enabler of offshore tax evasion or non-compliance in five years. That is a dramatic decline that sends the wrong signal. It also risks creating the impression that while most people must play by the rules, those with the right advisers can simply play around them. Since the introduction of a new corporate criminal offence of failure to prevent the facilitation of tax evasion in the Criminal Finances Act 2017, we have seen very little enforcement. When prosecutions are rare, deterrence weakens; when enforcement is inconsistent, compliance declines; and when those who break the rules see others doing so without consequences, the entire system begins to fray.