Guidance

Large businesses: other roles and responsibilities

Measures and approaches which may affect large businesses: including Senior Accounting Officer and tax compliance risk management.

Senior Accounting Officer

The Senior Accounting Officer (SAO) measure was enacted in the Finance Act 2009 as Schedule 46.

The SAO is a measure aimed at reducing the tax gap through improvements in businesses’ tax governance and systems. The measure requires a qualifying company to identify who its SAO is and for this person to take reasonable steps to ensure that the company has appropriate tax accounting arrangements in place. HM Revenue and Customs (HMRC) sees open and transparent discussions with qualifying companies about their tax accounting arrangements as key to the successful application of this measure.

HMRC has produced guidance on how the SAO measure applies to companies and how it operates the legislation.

Tax Compliance risk management

HMRC’s day-to-day approach to working with large business customers to manage their tax compliance risk is set out in the tax compliance risk management framework. The key elements are:

  • to build and maintain effective relationships with their customers
  • to classify their customers as low risk or not low risk so that they can target their resources on those customers who represent the greatest risk
  • for those customers who are not low risk to understand in what respects they are not low risk so that HMRC can target their resources in those areas

HMRC decides a customer’s overall level of tax compliance risk by:

  1. Considering the inherent risk they represent (in terms of, for example, their size, complexity and the amount of change they are subject to).
  2. Looking at whether or not they effectively mitigate this risk through their behaviour (for example, their attitude to tax avoidance, their systems and processes and their openness with HMRC).

This is done during the periodic business risk review, which is a collaborative process between the customer and HMRC. With the right behaviour any customer, regardless of their size or complexity, can benefit from low risk.

You can find more information on the detail of the approach in the Tax Compliance Risk Management manual.

Oil, gas and mining sector

This sector is responsible for the taxation of businesses operating in the UK’s oil industry and for the administration of the special tax regimes which apply to these businesses.

Engaging with large businesses and agents

Business Tax Forum

The Business Tax Forum (BTF) exists to improve the operation of the tax system for both HMRC and large businesses.

The role of the BTF is to foster a stronger relationship and greater understanding between large businesses, HMRC and HM Treasury, taking a strategic-level view and aiming to improve the:

  • administration of the tax system
  • implementation of government policy
  • understanding of the commercial environment
  • awareness of the concerns of business

The Forum meets on a quarterly basis.

Big 4 Heads of Tax

HMRC meets with the Big 4 Heads of Tax to foster a stronger relationship and greater understanding between HMRC and the agents dealing with large businesses and to improve the operation of the tax system for HMRC, agents and the businesses they serve.

These meetings offer a mechanism to:

  • debate issues in an atmosphere of mutual trust
  • engage about administration of the tax system and implementation of tax policy
  • improve the service provided by HMRC to its large business customers
  • consult on proposed changes affecting large business customers
  • discuss operational aspects of the tax system with HMRC and the development of HMRC’s Large Business Strategy, amongst other initiatives

Large Corporates Forum

The purpose of the Forum is to enable the large business to:

  • get closer to its customers
  • better understand their needs
  • act as a sounding board to test ideas, debate current issues and provide customers with another avenue to contribute to developing thinking on new legislation

It is not intended to replace or displace the many existing links between HMRC and representative bodies, such as the Business Tax Forum. It’s aim is to supplement them by providing a direct channel between large business and its customers which is more operationally focused.

Specifically, the Forum enables the large business to:

  • better understand the needs of its customer and so improve the service it provides
  • identify the compliance burden on customers with a view, where practicable, to taking measures to reduce it

If you wish to participate in the debate, you can register interest by emailing nicola.donnelly@hmrc.gsi.gov.uk.

Mid-Tier Agents Forum

The Mid-Tier Agents Forum (MTAF) is intended to foster a stronger relationship and greater understanding between HMRC and mid-tier agents dealing with taxpayers with complex affairs.

The MTAF offers a mechanism for those agents to:

  • debate issues in an atmosphere of mutual trust
  • engage about administration of the tax system and implementation of tax policy
  • improve the service provided by HMRC to customers
  • consult on proposed changes affecting customers
  • discuss operational aspects of the tax system with HMRC amongst other initiatives

Large Law Firms Forum

HMRC meets with representatives of the 5 largest UK law firms to discuss topical issues and specific items of tax administration and operation. This allows HMRC to gain a greater level of understanding and insight of these firms and their clients.

The forum offers a mechanism to:

  • debate issues in an atmosphere of mutual trust
  • engage about the administration of the tax system and implementation of tax policy
  • improve the service provided by HMRC to its large business customers
  • consult on proposed changes affecting large business customers
  • discuss operational aspects of the tax system with HMRC

For further details about the Large Law Firms Forum please email matthew.atyeo@hmrc.gsi.gov.uk.

Resolving tax disputes

High Risk Corporates Programme

The High Risk Corporates Programme is a cross-directorate initiative. The aims are to:

  • resolve tax disputes of very large businesses by agreement or litigation
  • reduce the scale of risk for the future
  • improve the relationship between HMRC and its large business customers
  • improve HMRC’s capability to deal with the largest and most complex tax risks

Large business surveys

HMRC carries out regular surveys to improve its understanding of large business tax compliance and the quality of service it provides to these businesses.

Published 10 October 2014
Last updated 14 October 2015 + show all updates
  1. email details for large law firms forum updated.
  2. First published.