Following consultation on its business risk review (BRR) process for large businesses HMRC has accepted the need to revise its approach in particular to: expand the current risk categories from just two (low risk/non-low risk) into a range which distinguishes more clearly between low and high risk; take more account of tax risk management work already required by large businesses such as the SAO provisions and the publication of tax strategies; provide taxpayers with a clear set of actions and timelines which need to be regularly updated and discussed with HMRC; and ensure consistency in allocating a certain risk rating and in particular a low risk rating should only be provided to large businesses that adhere to the OECD’s ‘tax control framework’ or have similar controls in place. HMRC will pilot a revised BRR later this year across a defined group of taxpayers ...
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