Guidance

Large business: The High Risk Corporates Programme

An overview of the High Risk Corporates Programme.

• From: HM Revenue & Customs
• Published: 15 February 2012
• Last updated: 12 May 2021 — See all updates

The High Risk Corporates Programme resolves large and complex tax risks presented by some of the UK’s biggest businesses.

Overview

The High Risk Corporates Programme was introduced by HMRC in 2006. The aims of the programme are to:

• resolve tax issues and disputes of large businesses using agreement or litigation
• reduce risk for the future by influencing businesses to change their behaviour and their approach to tax planning
• improve the relationship between HMRC and its large business customers
• improve HMRC’s capability to deal with large and complex tax risks

HMRC chooses cases suitable for the programme by looking at the size of open risks across all taxes. We also consider businesses’ tax and relationship strategies.

Main elements

The main elements of the programme are:

• discussions taking place at a senior, board level between HMRC and businesses
• HMRC working directly with businesses to investigate and discuss any technical issues
• HMRC oversight of the programme through our involvement in a cross-directorate steering group
• the involvement of specialists from across HMRC and, where needed, external legal counsel

Decisions on each case are made in line with the Litigation and Settlement Strategy.

Published 15 February 2012
Last updated 12 May 2021 + show all updates

1. 12 May 2021

   A routine review of the content, simplified terms used and a link to the litigation and settlement strategy added.

2. 15 February 2012

   First published.