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HMRC internal manual

Tax Compliance Risk Management

Managing our relationship with large business customers: working with Low Risk customers: what we expect of our Low Risk customers

We expect to be told in real time of significant transactions where:

  • there is a high level of judgment needed to determine the correct tax treatment;
  • the transaction is structured to ensure a particular tax outcome;
  • the tax analysis differs from our known views; or
  • there is a range of possible tax outcomes and the chosen outcome is towards the most tax-advantageous end of the range.

In general, real time should be taken to mean when the tax treatment of a transaction is being considered rather than after a return has been made. HMRC issues guidance‘Risk assessing: factors which may indicate avoidance’ (GOV.UK) on the sorts of factors which may indicate tax planning which HMRC deems to be unacceptable and these may be helpful in deciding whether or not a particular transaction should be raised with the CRM in real-time.

We also expect Low Risk customers to

  • give us advance warning of any significant or potentially contentious Voluntary Disclosures; and
  • share with us their approach to identifying and managing tax compliance risk across the business.

More detailed information on the criteria HMRC use to assess Low Risk is given later in this guidance in the section on Business Risk Review Assessment Indicators.

If a Low Risk customer ceases to meet these expectations see TCRM2470.