Tax Enquiries
into Large
Businesses

Support for finance directors, heads of tax and in house teams managing HMRC enquiries, Customer Compliance Manager relationships and Business Risk Review+.

HMRC does not investigate large businesses in the way it investigates individuals. Once a business reaches a certain scale, it moves into HMRC’s Large Business directorate, is assigned a Customer Compliance Manager, and enters a regime built on continuous relationship management rather than discrete enquiries.

That arrangement is less comfortable than it first appears. Continuous engagement means continuous scrutiny, and the risk rating HMRC assigns to your business determines how much of it you receive, for years at a time.

The Business Risk Review+ regime

Businesses within Large Business are subject to Business Risk Review+ (BRR+), HMRC’s structured assessment of tax compliance risk. It examines three areas: systems and delivery, internal governance, and the business’s overall approach to tax compliance.

The output is a rating of low, moderate, moderate to high, or high risk, and that rating has significant consequences. Low risk businesses receive a lighter touch and a review approximately every three years. Higher ratings mean more frequent reviews, more enquiries, more information requests and considerably more management time.

BRR+ is not a passive process. It is preceded by questionnaires and typically concludes with a substantial meeting. Businesses that prepare properly, evidence their governance and articulate their approach coherently tend to achieve better outcomes than those that treat the review as a formality. Over a three-year cycle, that difference has a material commercial value.

Where large business enquiries typically focus

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Transfer pricing and cross border arrangements

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Corporate interest restriction and financing structures

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VAT, including partial exemption, place of supply and complex supply chains

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Employment taxes, off-payroll working and IR35 status determinations

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Research and development tax relief claims, an area of sustained HMRC challenge

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Capital allowances and the treatment of large expenditure

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Senior Accounting Officer certification and the personal liability attaching to it

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Corporate Criminal Offence procedures under the Criminal Finances Act 2017

How we support large business enquiries

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BRR+ preparation
Working through HMRC’s assessment areas in advance of the review, identifying where the evidence is thin, and helping you present governance and controls in the way HMRC’s framework expects.

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Managing the enquiry
Coordinating information requests across the business, controlling scope, and ensuring that a question about one tax does not become an enquiry into three.

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Technical argument
Building the position properly, with legislation and case law, and engaging HMRC’s technical specialists on equal terms.

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The Customer Compliance Manager relationship
This is a long-term relationship and worth managing deliberately, because a CCM who has confidence in the business’s processes engages differently from one who does not.

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Escalation and resolution
Alternative dispute resolution, formal appeals and tribunal proceedings where a position cannot be agreed.

What to do if FIS contacts you

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Do not respond substantively before taking advice. Acknowledging receipt is appropriate. Answering questions is not, because early answers are difficult to retract.

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Do not destroy, alter or reorganise any records. Beyond being an offence in its own right, it is one of the quickest ways to turn a civil case into a criminal one.

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Establish which route you are on. Code of Practice 8, Code of Practice 9 and criminal investigation each call for a completely different response.

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Obtain representation with genuine FIS experience. This is not general practice work.

Our large business experience

Our specialist-led tax enquiry work for large corporate clients at one of the UK’s largest accountancy firms.

For finance directors and heads of tax

Much of the value here does not lie in the technical argument, which your team may well have covered. It lies in having an adviser who has worked within HMRC’s process, who can read what the enquiry is about, and who can give your board a realistic assessment rather than an optimistic one. We also work alongside in-house tax teams rather than around them. We routinely act as specialist support to in-house finance and tax teams on discrete enquiry aspects.

Frequently asked questions

What size of business does Large Business cover?

Broadly the largest UK businesses by turnover and complexity, commonly cited as around £200m turnover and above, although HMRC applies complexity criteria as well as size.

Can our risk rating be improved?

Yes. It is a reasoned assessment against defined criteria, and businesses that address the underlying issues and evidence the improvement do move ratings.