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:
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.
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Systems and delivery
- Documented tax policies and procedures
- Tax risk and controls matrix
- Resource and skills
Approach to tax compliance
- Tax strategy
- Corporate criminal offence
- Senior accounting officer (SAO)