Ex Tax Inspector explains HMRC's vigorous business tax enquiries into the largest corporates

LONDON - EntSun -- Amit Puri looked at HMRC's business tax enquiries into the UK's largest corporates, carried out by (i) Large Business ("LB") directorate and (i) the Wealthy & Mid-sized Business Compliance ("WMBC") directorate.

His latest full article for FT Adviser makes for good CPD learning and included Practical Considerations too: Understanding HMRC's vigorous tax enquiries into the largest corporates

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What is a Customer Compliance Manager?

HMRC try to ensure continuity and a deeper industry specific understanding of the businesses they monitor and enquire into; so appoint a dedicated customer compliance manager ("CCM").

• HMRC's LB manage, constantly review and assess the very largest UK businesses, which typically have annual turnovers of over £200m, or lower due to complexity. There are reportedly approx. 2,000 such large businesses in the UK.
• HMRC's WMBC enquire into large businesses, typically with annual turnovers of £10m or more; there are estimated 160,000 in recent years. But instead of a permanent CCM – as in LB – who is tasked with encouraging voluntary compliance, in WMBC the focus is on identifying and carrying out cross-taxes enquiries.

What is a Business Risk Review in LB?

A business risk review ("BRR") is supposed to be a collaborative evaluation of potential tax risks, conducted between the business concerned and HMRC – led by the named CCM. HMRC will deploy a team usually, to cover the different taxes involved and an industry / sector specialist.

The key objectives of this BRR include determining the business' overall tax risk rating and status, outlining any actions to take to reduce tax risk, and identifying the resources and scrutiny required.

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For businesses with low-risk ratings, the full assessments are done every three years, while moderate to high-risk businesses undergo annual BRRs.

What is a cross-taxes Business Enquiry in WMBC?

The next most resource intensive type of enquiry carried out into large corporates is often referred to as 'full' or 'cross-taxes'. As above, these are often led by a CCM too who brings with them a team of specialists, typically covering VAT and employer duties like PAYE and NICs in addition.

In practice, the CCM will usually ask for a meeting with the business owners if they're materially involved in the business' operations, as well as those responsible for the record keeping and accounting and tax preparation.

HMRC will not waste any time in asking for a comprehensive download of the electronic business and accounting record; sometimes before the initial meeting. This stage must be handled with great care.

Next, armed with a huge volume of business and accounting records, HMRC will identify tax risks for their team's pursuit. They typically organise themselves internally by creating an Action Plan, which their various specialists feed into.