Updated guidance has recently been published for HMRC's Business Risk Review 2019 process, known as BRR+.

This new Business Risk Review guidance applies to all large companies from 1 October 2019 and moves away from the previous two-category system of Business Risk Review as either low-risk or "non-low" to a new four-category sliding scale of tax risk.

Who is affected by the new HMRC Business Risk Review guidance?

The new BRR+ approach will be implemented across all large firms, but we anticipate it may also become HMRC's new business risk review model for mid-sized companies in the years ahead.

Summary of Business Risk Review legislation changes

The new BRR+ process introduces the following risk categories:

  • Low
  • Moderate
  • Moderate-high
  • High

The new system allows businesses to benefit from active tax risk management. The new approach also takes into account that even complex international businesses can be considered low risk, provided they can demonstrate they have addressed certain risk factors.

Under BRR+, HMRC will gauge the size, scope and depth of a business. Through this process, HMRC is seeking to identify how behavioural risk factors reduce or increase the inherent risks present in the business. In addition, HMRC has laid out comprehensive guidance and assessment indicators detailing how it assesses risk factors in three key areas, each having different requirements to achieve a low-risk rating.

Partner Lee Holloway

+44 (0)20 7728 2650

Find out more

Systems and delivery

  • Documented tax policies and procedures
  • Tax risk and controls matrix
  • Resource and skills

Approach to tax compliance

  • Tax strategy
  • Transparency

Internal governance

  • Corporate criminal offence
  • Senior accounting officer (SAO)

What does a Business Risk Review rating mean for you?

For those assessed as low risk: interactions with HMRC will, in general, be driven by the assessed rather than HMRC, with risk reviews being conducted on a three-year cycle.

For those assessed as high risk: expect targeted interventions from HMRC, with a likelihood of several meetings being necessary each year, as well as full annual Business Risk Reviews.

How we can help improve your Business Risk Review

Our tax risk management specialists have in-depth experience and knowledge of HMRC’s Business Risk Review processes. We can share practical experience and insight based on our work with other businesses in similar sectors.

We can also:

  • Assist with fulfilling the Criminal Finances Act 2017 requirements, ensuring that suitable risk controls are in place. Our approach is scalable and industry specific
  • Assist with tax risk requirements such as preparing a risk register and documenting tax controls and procedures
  • Review your tax accounting arrangements in line with the SAO regime. We can carry out a full review of controls and procedures or review your existing approach to SAO
  • Help senior management understand recent changes in the tax risk environment and what is considered to be best practice
  • Provide additional resource and training to support your business through key compliance changes and where tax risks are identified such as Making Tax Digital and IR35