On 19 March, HMRC published their response to the business risk review (BRR) consultation. The headline is that any change to the BRR process will not take place until 2019/20 to allow for Brexit and making tax digital to develop further. However HMRC have provided a clear signal of intent noting that tax strategies and SAO should be considered together. We understand that the tax strategy should form the basis of your relationship with HMRC with SAO providing the evidence that you are living your tax strategy in practice. HMRC note that both SAO and tax strategy are underpinned by the concept of a Tax Control Framework ("TCF") and companies operating an effective TCF should be rewarded.
We have included further detail below but if you would like to discuss the HMRC response in detail and in particular the interaction between tax strategy, SAO and TCF going forwards, please contact Ray Farnan, Ben Proctor, or Andy Olymbios.