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HMRC internal manual

Tax Compliance Risk Management

The Business Risk Review (BRR): Revisiting the BRR: Low Risk customers

For existing Low Risk customers BRRs will normally take place on a three year cycle from the date that the last BRR was shared with the customer (the exact period will be agreed between the Deputy Director and the CRM). Where open communications have occurred during the intervening period and the CRM has maintained their understanding of the customer’s business, the Business Risk Review should be able to be completed with minimum effort on both sides. In revisiting the Business Risk Review for Low Risk customers we will:

  • not examine every return and computation that has been submitted to HMRC in the previous three year period;
  • only examine a return if it is necessary to do so for the customer to maintain its Low Risk status;
  • not make retrospective enquiries.

Risk Assessment of specific tax returns should not be carried out as part of the BRR for an existing Low Risk customer without the agreement of the CRM. If this is agreed it should only be carried out on the returns covering the most recent 12 month period. If at any point a change from Low Risk status is proposed this should be agreed by the Deputy Director, or their nominated Assistant Director (see TCRM 3430).