HRMC’s tax clear-up programme will impact a number of large corporates whose tax approach is considered high risk or where potential recoverable revenue is significant with regard to unresolved issues. Tax Directors, where appropriate, could request entry into the programme but the advantages and disadvantages of doing so should be carefully considered. A proactive approach may result in improved relations with HMRC, ‘peace of mind’ and a better financial outcome and long-term risk rating, however the cost and time implications as well as the complexity of the negotiations and disclosures need to be weighed up against the potential advantages.