UTT15400 - Notification process: interaction of notification with business risk reviews and senior accounting officer certificates

For customers dealt with by HMRC’s Large Business directorate for whom Business Risk Reviews are undertaken, there is no direct read across from a notification being made to a risk rating. This means for example that making a notification does not automatically mean a business cannot be low risk. However, it is important to consider the nature of any notification, or notifications, and what it is indicating about a customer’s approach to tax compliance and engagement with HMRC in line with the Low Risk Criteria in TCRM3660. HMRC expects low risk businesses to discuss transactions or issues with significant tax implications in real time and to manage communications with HMRC collaboratively.

For customers within the Senior Accounting Officer (SAO) reporting requirements, if there is an Uncertain Tax Treatment (UTT) issue and it is unresolved at the time an SAO certificate is due it is unlikely to have any consequences on SAO certification. The primary focus of SAO is ensuring companies have effective accounting processes in place, whereas UTT is identifying specific uncertain transactions. HMRC wouldn’t ordinarily expect an SAO certificate to automatically be qualified due to a UTT notification.