What is Business Risk Review Plus (BRR+)?
The Business Risk Review Plus (BRR+) framework is central to how HM Revenue & Customs (HMRC) evaluates the tax compliance behaviours, systems and governance of the UK’s largest and most complex businesses. It provides a structured assessment of overall tax risk and plays a key role in determining the level of scrutiny a business may experience from HMRC.
BRR+ applies to organisations with a dedicated Customer Compliance Manager (CCM) within HMRC’s Large Business Directorate. This typically includes businesses with UK turnover over £200 million a year, companies forming part of multinational groups, and organisations with more complex tax affairs.
Why BRR+ matters for large businesses?
BRR+ is important because it directly influences HMRC’s future approach to a business’s tax affairs. A strong BRR+ rating can also provide confidence to boards, shareholders, auditors and other stakeholders that tax governance is effective. Conversely, a less favourable rating may result in more frequent reviews or increased HMRC focus.
How HMRC assesses businesses under BRR+?
BRR+ evaluates three key behavioural factors as part of its approach to categorising large business for risk purposes:
Systems and delivery
This factor reflects whether the business has systems and processes that are suitable for its size and complexity, supported by sufficient skilled resource to deliver timely and accurate returns, declarations, payments and claims. It includes having a tax team with appropriate skills and capacity, making all returns and payments on time, and ensuring that any interventions have not identified significant errors. It also includes maintaining and sharing a tax risk and controls matrix, documented tax policies and procedures, and evidence of assurance checks and testing, as well as demonstrating that any outsourced tax-related activities are properly monitored.
Internal tax governance
Internal governance involves having clear accountabilities up to and including the board for managing tax compliance risk and tax planning, and maintaining appropriate tax accounting arrangements that enable accurate tax reporting. It includes keeping HMRC informed about how the business is structured, and fulfilling all obligations for the Senior Accounting Officer (SAO) legislation, Uncertain Tax Treatment (UTT) legislation, Country by Country Reporting (CbCR), transfer pricing records regulations, Organisation for Economic Co‑operation and Development (OECD) Pillar Two top‑up tax and Automatic Exchange of Information. It also covers managing risks under the Corporate Criminal Offence legislation, communicating uncertainties or irregularities promptly, discussing significant transactions or issues in real time, and providing prompt, accurate and helpful responses to information requests.
Approach to tax compliance
This factor focuses on maintaining an open and transparent relationship with HMRC, supported by a documented tax strategy that guides tax considerations and is regularly reviewed. It includes openness in real time about how tax compliance risk is managed, avoiding tax planning that doesn’t support genuine commercial activity, and avoiding structuring that gives a tax result contrary to the intentions of Parliament. It also includes taking steps to mitigate illicit trade risks within supply chains and having no inaccuracy penalties, including suspended penalties.
The BRR+ process: what to expect
A BRR+ generally involves HMRC:
- Working with the business to understand the landscape in which the business operates and how this may affect its inherent tax risk.
- Assessing the effect on this inherent risk of the business’s behaviours across each applicable tax regime.
- Considering the overall risk rating of the business.
- Agreeing the business’s overall risk status.
- Agreeing any actions to reduce the risk level.
BRR+ is intended to be a collaborative process, with HMRC encouraging businesses to form their own view of how they measure up against the BRR+ criteria and to share this with their CCM. Discussing areas of alignment, as well as any differences, can help both sides reach a clear and agreed understanding of the appropriate risk rating.
BRR+ risk ratings
BRR+ results in one of four ratings:
- Low.
- Moderate.
- Moderate-High.
- High.
A business with a low-risk rating is likely to only have to go through the BRR+ risk review process with HMRC every three years. All other businesses will have their risk status reviewed at least annually.
The rating helps determine the level of ongoing HMRC engagement and where HMRC may focus future enquiries or interventions.
How large businesses can prepare for BRR+ in 2026?
To prepare effectively for BRR+ reviews, businesses should focus on:
Documented governance
Maintain clear evidence of tax controls, processes and responsibilities, including tax risk registers or control matrices.
Operational effectiveness
Ensure systems, processes and teams can demonstrate how tax filings are prepared, reviewed and monitored.
Constructive engagement with HMRC
Establish open, timely and balanced communications with HMRC.
Responsiveness to change
Update processes promptly when business operations, systems or structures change.
Proactive engagement
Be prepared to explain tax positions, areas of judgment and any improvements made since the last review.
How Saffery supports businesses through BRR+?
Our team of corporate tax experts support large businesses at every stage of the BRR+ process. We can help you:
- Assess systems, governance and behaviours against BRR+ criteria,
- Improve tax risk management and documentation,
- Prepare for CCM BRR+ interactions,
- Identify potential risk areas, and
- Work towards achieving or maintaining a low-risk rating.
Whether you are approaching your first BRR+ assessment, preparing for an upcoming review or looking to improve your existing governance, we can support you.
