TCRM2470 - Managing our relationship with large business customers: working with Low Risk customers: withdrawal of Low Risk status

If we have reason to believe that a Low Risk customer is no longer meeting low risk behavioural expectations, for example, because:

• they refuse to meet with the CCM,
• they have entered into tax avoidance schemes,
• they have not raised a significant tax uncertainty with HMRC in real time,
• there is a significant deterioration in promptness of returns and / or payments

the CCM will try to resolve this with the customer. If the customer does not make reasonable steps to satisfactorily address the issue within an agreed timeframe then the CCM may withdraw Low Risk status. Any decision to do this must be made with the agreement of the BRR+ Countersigning Officer, as described in TCRM3430.

In the most serious cases where a Low Risk customer no longer meets low risk behavioural expectations or directly engages in behaviour which in HMRC’s opinion is high risk such as, but not limited to :

• an aggressive tax avoidance scheme
• gross lack of transparency
• a grossly negligent error
• fraud

there may be nothing the customer can do immediately to restore HMRC’s confidence. In such circumstances the CCM may immediately withdraw Low Risk status regardless of the current point within the Business Risk Review + cycle. Any decision to do this must be made with the agreement of the BRR+ Countersigning Officer . The customer’s future behaviour will then be considered through the BRR+ process, falling within one of the four ratings (Low Risk, Moderate Risk, Moderate - High Risk or High Risk).