TCRM4400 - Risk Assessment: Revisiting the BRR+

As Risk Assessment work is carried out, the CCM should make sure that the existing Business Risk Review is revisited and the customer’s overall risk rating re-evaluated. The revised BRR+ should be shared with the customer, using the BRR+ template and the particular tax compliance risks or further Risk Assessment activity discussed and planned.

We expect customers to seek a Low Risk rating but may need a period of time to demonstrate that they have achieved this level of assessment. For example, the initial assessment may identify a failure of governance or inappropriate use of systems to deliver the right customs or taxation outcome. This will need to be clearly identified in the BRR+ and resulting Action Plan. If the customer indicates that they would like to achieve Low Risk more quickly than the 12 month cycle this should be encouraged. Customers should be asked to confirm how they will address any weakness and over what period and if appropriate the CCM may agree to reassess the rating ahead of the 12 month cycle. The re-review should focus on the issues identified but also be aware of any behaviour in the intervening period. Moving to Low Risk will secure better compliance earlier, supports our drive to work in real time and allow the customer to move to a three year cycle more quickly.