Details of the risk-based approach developed by HM Revenue and Customs to dealing with its largest and most complex business customers.
HM Revenue and Customs (HMRC) has developed an efficient risk-based approach to dealing with its largest and most complex business customers. This is based on an understanding of their particular needs and how they respond.
The current model of relationship management is an approach to dealing with tax matters which looks to provide certainty, clarity, proportionality and speed of resolution, underpinned by high levels of professionalism and commercial understanding.
Using feedback from customers, businesses, representative bodies and stakeholders HMRC set out 6 objectives which it aims to have fully delivered by the end of 2014 to 2015:
HMRC will invest in a resource-intensive, relationship-managed service for the largest customers, because the money and complexity involved make this the most cost-effective way of getting the right tax agreed early.
All parts of HMRC will work within a common set of risk priorities. HMRC will prioritise the highest risks. HMRC will resource to risk by customer behaviour, by threats to regimes and by size and complexity.
In dealing with those who bend the rules, HMRC will prioritise ‘upstream’ effort, firstly changing behaviour through policy design and disclosure, then through rigorous case working and where possible within established relationships and finally, where appropriate, through litigation.
HMRC will always seek to work issues in real-time with all customers no matter what their tax strategy, which not only provides earlier certainty for the customer but also allows HMRC to detect avoidance more quickly.
HMRC customers should have, or should buy in, the skills to fulfil their ordinary day to day tax compliance requirements, but HMRC will provide assistance to resolve uncertainty around complex or significant issues and commercial transactions.
All processing for large business customers will be via the normal channels. All contact, compliance interventions and exceptions will be co-ordinated through a Customer Relationship Manager (CRM) ensuring coherent customer management.
What HMRC will deliver
Customers with a CRM
By fully delivering these 6 objectives, HMRC’s aim is that most customers with a CRM might say the following in 2014 to 2015:
- I am up to date with all years closed up to 2012, apart from an issue on EU law that we are litigating, it was difficult to get there, but we achieved it through a willingness on both sides to face some tough decisions
- I work with HMRC daily on many significant and commercially important issues - whether HMRC has raised them or because I have raised them because I want commercial certainty - only rarely does something take longer than expected to resolve, in which case I am made aware of the reason
- the main method of communication is now face-to-face or telephone rather than letters, HMRC is transparent about its thinking - where it differs from ours, HMRC explains why - I feel that HMRC listens and wants to understand our position
- I get a sense that HMRC has a real grasp of the key tax risks from the questions I’m asked - HMRC’s officers show a marked improvement in their commercial understanding, applying their tax knowledge to my business and asking about the right things
- there is a noticeable improvement in the way that they deal with all risks, in particular with VAT and on employer compliance risk issues, HMRC is now much more proactive and drives the risk agenda - the CRM has improved their focus and I can see a real step change in their confidence and skills in meetings, whatever the tax issue
- my relationship with HMRC is professional - we are open with each other and there is trust on both sides, in particular, I can discuss all our potential tax planning opportunities transparently with my CRM in real-time, there’s no point in not being transparent and we all want to protect our working relationships
- I may buy good ideas from the Big Four/Magic Circle (or other agents and advisers) to ensure that my effective tax rate remains competitive, even so I avoid aggressive schemes because our relationship with HMRC is too important to risk losing it for a one off saving - additionally being re-categorised as a non-low risk business is unattractive as I know that HMRC will pursue all risks vigorously
- I only contact my CRM when I am dealing with issues that are particularly complex or significant, otherwise my day-to-day tax affairs are managed in-house or through an agent
- the big change from recent years is the CRM interaction with their technical specialists, I feel that the CRM now has a grip and is firmly in the centre of everything so that discussions are focused around our business and what is important for us - they make sure we all understand each other, and that issues are resolved as quickly as possible
- I feel I am consulted and have a voice, either through the CRM or directly, in changes that HMRC make and in wider policy change