HMRC uses the BRR+ process to review organisations’ business risk control level from a tax perspective. It was introduced in 2019 to help influence taxpayer behaviour and ensure risk profiles are reflected accurately. It governs the level of review and intervention from HMRC.

There are four risk categories: 

  • Low
  • Moderate
  • Moderate-high
  • High

Business Risk Reviews are undertaken by a business customer compliance manager (CCM) at HMRC. CCMs are allocated to large businesses (those who generate more than £200m of UK turnover and/or £2bn gross assets) and act as the business’s designated HMRC contact.

During the BRR+ review, HMRC looks at 24 low-risk indicators that reflect the robustness and business risk management of a company's tax governance, frameworks, procedures, guidelines, oversight and risk handling strategies across three areas:

  • Systems and delivery
  • Internal governance
  • Approach to tax compliance 

The benefits of a proactive approach to the BRR+

  • HMRC’s questionnaire and information request are a large part of the BRR+ process. It can be time-consuming for a business to pull together responses and documentation. Early preparation and establishing best practices will help the business have all the relevant documentary evidence available
  • The BRR+ process is designed to be collaborative. A business should use this as an opportunity to improve its relationship with HMRC, hold open discussions about any issues the business is facing and take HMRC’s comments on board
  • Early preparation can increase the likelihood of achieving a low-risk rating, which can reduce the level of intervention by HMRC and result in less frequent reviews
  • A proactive approach to BRR+ readiness means the business is more likely to drive interactions with HMRC rather than the other way around

How S&W can work with you on your BRR+

We have helped many businesses prepare for a BRR+ and can provide assurance in line with your peers and best practice. We generally provide support in three stages:

  • Phase 1 – A tax health check across all taxes, along with preparation of an action plan
  • Phase 2 – Addressing key areas and meeting preparation
  • Phase 3 – Support throughout the BRR+ process –
    • Advice on conducting the review
    • Review of the agenda and information request by HMRC
    • Input into the BRR+ or review proposed meeting slides 

For businesses that have already performed a BRR+, we can support a refresh, reviewing the business’s risk control and tax risk to reflect any business changes and existing policies and procedures to identify any changes required.

Contact us today if you have any questions or to discuss the BRR+ or how we can support you. 

Frequently asked questions about Business Risk Review

During the BRR+ review, HMRC looks at 24 low-risk indicators across three areas:

  1. Systems and delivery is about assessing the ability to deliver the right tax at the right time. Examples of low-risk indicators include the following:
    • All returns and payments are made on time
    • The business maintains a tax risk and controls matrix and shares this on request from HMRC
  2. Internal governance is about assessing management accountabilities and processes for managing tax risk and openness and cooperation with HMRC. Low-risk indicators are as follows:
    • The business has clear accountabilities up to and including the board for managing tax compliance risk and planning
    • The business appreciates its potential liability under corporate criminal offence legislation and has taken steps to profile and manage the risk of failing to prevent the facilitation of tax evasion
  3. Approach to tax compliance is about assessing the tax strategy and relationship with HMRC. Examples of low-risk indicators include:
    • The business maintains an open and transparent relationship with HMRC
    • It has a documented tax strategy used to steer all tax considerations

Most businesses aim to be classified as low-risk. This will translate to less intervention from HMRC and less regular HMRC reviews (generally carried out on a 3–5 year cycle).

However, some businesses decide that a moderate risk rating is more in line with their business, given their complexity, and believe this gives them better communication with HMRC when they need it. A moderate risk rating may also give tax issues more traction across the business.

It ultimately depends on the business, and we work with our clients to manage the risk and the process accordingly.

This depends on your business’s rating, but as a rule of thumb, your organisation can expect to go through the BRR+ process every one to three years. A higher risk rating will result in more frequent reviews, with HMRC’s factsheet stating that this will usually be annual.