Large business: The High Risk Corporates Programme

Aims and elements of The High Risk Corporates Programme.

The High Risk Corporates Programme is a cross-directorate initiative.


The aims are to:

  • resolve the tax issues of very large businesses by agreement or litigation
  • reduce the scale of risk for the future
  • improve the relationship between HM Revenue and Customs (HMRC) and its large business customers
  • improve HMRC capability to deal with the largest and most complex tax risks

The programme selects suitable cases by looking at the scale of open risks across all taxes and considering the customer’s tax and relationship strategies.

Key elements

Key elements of the programme are:

  • Board to Board engagement
  • a very high level of governance under the monthly cross-directorate Programme Board
  • rigorous investigation and debate of technical issues with customers, face to face and to a detailed agreed project plan where possible
  • effective partnership working across directorates and with external counsel and others
  • resolution decisions fully in line with the Litigation and Settlement Strategy
Published 15 February 2012