Maintaining a good risk rating with HMRC is a key focus for the tax departments of UK companies. The largest 2,000 organisations will have undertaken a Business Risk Review (BRR) with their Customer Compliance Manager (CCM) and been given a risk rating.
Following the announcement in 2017 that HMRC would be consulting on the Business Risk Review process, HMRC have now started to roll out their enhanced BRR+.
Welcome to your new classifications
In response to feedback on the consultation, HMRC are replacing the previous binary ‘low’ and ‘non-low’ risk classifications with a more granular ‘low’, ‘moderate’, ‘moderate-high’ and ‘high’ risk rating.
Companies that qualify for a low-risk rating would generally have BRR+ reviews carried out every three years by HMRC. Those with higher ratings will have a review at least once a year, diverting valuable time and resources away from the tax department.
HMRC’s company overview
Each tax type relevant to your organisation e.g. corporation tax, VAT etc is assessed against 3 categories considering the landscape in which the business operates. Then an overall summary rating is given to the company, it assesses the company’s current risk and identifies steps to reduce it.
The 3 categories for assessing the risk per tax type are:
- Systems and processes
- Governance
- Approach to tax compliance
By separately identifying systems and processes, HMRC are raising the bar for risk compliance in this area. We’ve previously discussed various reasons why tax teams need to invest in tax technology, and even produced a report with shocking stats around the challenges of current tax processes.
This is yet another opportunity for tax functions to improve tax compliance, accuracy and transparency with not only HMRC’s MTD mandate but also BRR+ initiate. In addition, for companies wishing to qualify for a lower risk rating they must demonstrate that they have adequate systems in place for each tax type.
How will HMRC assess the ‘systems’ criteria?
In total there are 8 indicators used to evaluate the systems and processes category, HMRC states that in order to be classified as “low” or “moderate” risk it’s necessary to meet the first two criteria. Failure to meet both will result in either a “moderate-high” or “high” risk classification for systems. The 2 essential criteria are:
- Systems and processes: The customer employ’s sufficient resource to deliver timely and accurate returns, declarations, payments and claims, including accounting systems and processes that are suitable for the size and complexity of the business.
- Sufficiently resourced tax team: The customer employs sufficient resource to deliver timely and accurate returns, declarations, payments and claims, including sufficiently skilled resource in the Finance/Tax teams
How will this affect companies?
As HMRC continue the digitalisation of their tax services, taxpayers will face ever-increasing pressure to file more frequently. This will draw additional attention to the systems companies have in place to not only submit their VAT but to ensure that their data is correct.
Many tax departments are already under immense pressure to meet current requirements, the need to fulfil these extra obligations will be incredibly difficult without further investment in resource or systems.
Robust and scalable tax technology – such as our platform for:sight – can provide a much-needed lifeline to overstretched tax teams, helping to ensure compliance with not only HMRC’s risk control but also MTD mandate. Minimising your overall risk rating and frequent BRR+ reviews from HMRC.
If you’d like to ensure you have the right systems and processes in place for BRR+, our for:sight platform can help to provide data transparency and accuracy to tax teams. Get in touch today for more information.