Customer compliance manager

Produced by Tolley

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

  • Customer compliance manager
  • Risk assessment
  • Low risk status
  • Senior accounting officers
  • Transactional risks
  • Large business service
  • The role of the customer compliance manager
  • Appointment of a CCM
  • Dealing with issues
  • Factual issues
  • More...

Customer compliance manager

A customer compliance manager (CCM), formerly known as a customer relationship manager (or CRM), is appointed for businesses dealt with by the Large Business Service (LBS) and for a selection of businesses dealt with by Local Compliance (Large and Complex) (L&C). LBS customers have a turnover of £600 million or above, or assets of £2 billion or more. An L&C customer is a business with turnover of £30 million or more or with more than 250 employees.

Generally, a CCM is allocated when the turnover of the business exceeds £200 million. Where there is no CCM for an L&C business, a customer co-ordinator will be appointed. Guidance regarding the CCM and customer co-ordinator roles can be found on the GOV.UK website.

Risk assessment

It is HMRC policy to classify its largest businesses as either low or not low risk, although occasionally expressions such as ‘intermediate’ can be encountered. A business risk review is undertaken for this purpose. See the Business risk review guidance note for further details of this process.

This means that the largest businesses can face rigorous and recurring scrutiny from HMRC if they are not classed as low risk. Conversely, businesses classed as low risk will have the bonus of reduced interventions but will still face the risk review process on a three-year cycle and will need to handle their tax affairs with HMRC on a real time basis.

HMRC’s strategy is to focus its limited resources on the areas it perceives to be of highest tax risk, and the interaction with low risk businesses is driven by the business rather than HMRC.

Low risk status

HMRC’s definition of low risk is a company which has an open and transparent relationship with HMRC, is effectively managing its own tax compliance risk, and which HMRC trusts will not engage in tax planning that does not support genuine commercial activity. See TCRM2100.

HMRC expects businesses classed as low risk to inform it in real time of significant transactions where:

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