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HMRC internal manual

Tax Compliance Risk Management

Risk Working: overview

This is work carried out to address a specific significant tax risk and should be planned with the customer using an Action Plan (AP). Risk Working should involve all the relevant specialists to ensure that the work is carried out as efficiently as possible. There are standard operating procedures (SOPs) for Risk Working which customer teams must follow.

In cases of ongoing serious risk we will assemble task-forces of expertise across HMRC, carrying out detailed and in-depth enquiries with greater intensity and to faster timescales, obtaining legal advice earlier and maintaining momentum by using our information powers as appropriate. Where we believe that a customer’s behaviour poses a serious tax risk we will engage directly at Board level to try to persuade that customer to change the behaviours that are generating those risks.

A Board needs to be aware that contentious tax enquiries and disputes are expensive and resource intensive. We will generally seek dialogue and offer a Board an alternative approach and will always support our customers in moving towards Low Risk. In deciding how matters should be resolved we will look at each issue on its own merits litigating where necessary in line with our published ‘Litigation and Settlement Strategy’. All significant tax settlements must be dealt with in accordance with the ‘Code of governance for resolving tax disputes’.