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HMRC internal manual

Tax Compliance Risk Management

The Business Risk Review (BRR): Business Risk Review Assessment indicators: Maintaining the audit trail

CRMs must ensure that they maintain a robust audit trail to support the decision they have made following the BRR. This should include:

  • the Customer Overview (CO) Document;
  • a completed overall Business Risk Review template supported by a BRR template for each tax regime;
  • notes of discussions with specialists, including colleagues outside LB, where appropriate, to support the overall risk markings;
  • notes of meetings with the customer to discuss and agree the BRR across all tax regimes;
  • notes of meetings (at least yearly) with the customer to discuss the customer’s tax affairs and compliance;
  • copies of the customer’s documented tax strategy (if there is one);
  • details of any intervention activity which has contributed to the CRM’s assessment of risk;
  • any evidence of customer’s governance and delivery, including the SAO certificate and the results of any Tax or Audit specialist activity on the company’s accounting arrangements;
  • for customers classified or re-classified as Low Risk, the BRR Audit Trail template.