TCRM2300 - Managing our relationship with large business customers: Overview of the TCRM process

The Tax Compliance Risk Management process is cyclical in nature and is different for customers who we identify as low risk and those who do not meet all the criteria for low risk;  instead falling within the categories moderate, moderate - high or high risk. The process for both types of customers is set out below -

For a new large business customer, the TCRM process involves the Customer Compliance Manager (CCM):

  •  developing and maintaining customer understanding
  •  carrying out an initial Business Risk Review (BRR+) to determine the customer’s overall risk status
  •  classifying the customer as:
    •      low risk
    •      moderate risk
    •      moderate–high risk
    •      high risk

If the customer is low risk

  •      The CCM will not carry out another BRR for two to three years.
  •      They will maintain an understanding of the customer during this period.
  •      If later BRR classify the customer as not Low Risk, they will move into the cycle for those customers set out below.

If the customer is not low risk

  •      Customers classified as moderate risk, moderate–high risk or high risk will enter the not low risk cycle.
  •      The CCM will:
    •  carry out Risk Assessment activity, which may lead to risk working
    •  complete a BRR+ every year
  •      If later BRRs classify the customer as low risk, they will move into the low risk cycle set out above.

This is a simplified explanation as HMRC will also occasionally undertake activity on low risk customers in between BRR+. This may include risk working activity, for example in relation to mandatory work.