Business risk review

By Tolley

The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Business risk review
  • Business risk review (BRR)
  • Definition of tax risk
  • The benefits of a low risk status
  • The risk assessment
  • Inherent risks
  • Behavioural risks
  • Risk review follow up
  • Attending risk meeting with HMRC
  • The risk review process
  • Steps a business can take in advance of an initial risk review meeting

Business risk review (BRR)

Companies dealt with by the large business service (LBS) and certain companies dealt with by local compliance (large and complex) (L&C) within HMRC will normally be subject to a BRR once a customer relationship manager (CRM) has been appointed, or if a review is requested. The overall aim of the review process is to assess the tax compliance risk profile of a company and categorise it as either low risk or not low risk.

Once an initial review has been completed, a company will be entered into a cycle of further reviews, the frequency of which depends on the allocated risk status.

The process will involve risk assessments in respect of all taxes and duties that the company pays or bears, with the areas of corporation tax, VAT and employer compliance being particularly common for most companies. HMRC will undertake various research activities, for example reviewing group websites, and will also hold a fact finding meeting with the company. A collaborative approach is encouraged, with input from tax, audit and other specialists.


A more detailed overview of the BRR process can be found at TCRM3100, together with a flowchart summarising the analysis undertaken by HMRC.

Consultation on the risk review process

HMRC has recently carried out a consultation with the aim of enhancing the risk assessment approach for large business compliance. The summary of responses  was published in March 2018. HMRC will now develop a new version of the BRR which will be piloted prior to being rolled out in 2019/20.

Several amendments have been proposed. It is possible that the number of risk categories will be extended beyond the current low risk / not low risk categories so that the risk profile of companies can be reflected more accurately. In addition, HMRC recognises that the enhanced BRR process

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