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HMRC internal manual

Tax Compliance Risk Management

HM Revenue & Customs
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Managing our relationship with large business customers: Working with Low Risk customers: HMRC-initiated activity: Introduction: Tax avoidance projects

We will want to test all instances of tax avoidance in accordance with HMRC’s Managing Avoidance Risk Process. All customers can expect that transactions or arrangements will be examined in detail where tax avoidance has been reported or suspected.

The use of tax planning that does not support genuine commercial activity or of transactions structured in a way that gives a result contrary to the intentions of Parliament are incompatible with Low Risk status.