What Is a Business Risk Review (BRR+)?

HMRC’s Business Risk Review Plus (BRR+) is the framework used to assess the tax compliance risk profile of large and complex businesses. At its core, BRR+ is about answering one question: “Can HMRC trust this business to get its tax right?”

The outcome of the review is a formal risk rating (Low, Moderate, Moderate-High, or High), which directly influences:

• The level of scrutiny applied by HMRC.
• The frequency of engagement and subsequent reviews.
• The likelihood of enquiries and intervention activity.

The process is typically led by a Customer Compliance Manager (CCM) and applies to large businesses (generally those with turnover >£200m or complex operations).

HMRC’s Current Approach (BRR+ Framework)

As a behavioral-led assessment, HMRC’s approach has evolved significantly in recent years. BRR+ places less emphasis on size and inherent risk and greater focus on how well a business manages that risk.

HMRC assesses businesses across three core pillars:

1.  Systems and Delivery

• Are systems, data, and processes robust and scalable?
• Are returns filed accurately and on time?
• Is there sufficient resourcing and technical capability?

2.  Internal Governance

• Is there clear accountability up to Board level?
• Are tax risks identified, documented, and monitored?
• Are obligations (e.g. SAO, UTT, CbCR, Pillar Two) fully met?

3.  Approach to Tax Compliance

• Is the business open and transparent with HMRC?
• Is the tax strategy clearly articulated and followed?
• Is tax planning aligned with commercial substance and legislative intent?

HMRC assesses businesses against a detailed set of low-risk indicators across the three pillars. The more indicators that are not met, the higher the risk rating.

Process and Timing

A typical BRR+ cycle involves:

• Pre-review data requests and questionnaires.
• HMRC forming an initial risk view ahead of the meeting.
• A review meeting (often 2–3 hours).
• Issuance of a final risk rating and action plan.

Recent Developments and HMRC Focus Areas

HMRC continues to refine BRR+ to reflect emerging risks and policy priorities, with several notable developments:

• Increased emphasis on evidence and substance.
  • Greater requests for supporting documentation.
  • Focus on how controls operate in practice, not just on policies.
• Integration of new regimes (e.g. Pillar Two).
  • BRR+ indicators now explicitly incorporate OECD Pillar Two requirements.
  • Expect scrutiny of how new obligations are embedded into the governance framework.

Practical Steps to Prepare for a BRR+

Preparation should start well in advance of the review. In our experience, the most successful engagements are those that treat BRR+ as an ongoing governance process, not a one-off event.

• Assess your current risk position.
• Strengthen your tax control framework.
• Enhance governance and accountability.
• Ensure documentation is “review-ready”.
• Prepare for the review meeting.

Final Takeaways

A strong BRR+ rating is not just about compliance, it is a clear signal of governance quality, operational control, and risk maturity. Businesses that invest early in governance, transparency, and controls are best placed to:

• Reduce HMRC scrutiny.
• Avoid disputes and penalties.
• Enhance stakeholder confidence.
• Support future transactions and exit readiness.

How Alvarez & Marsal Can Help

A&M’s Tax Risk and Dispute Management team provides end-to-end BRR+ support, including:

• Pre-review diagnostics and mock BRR exercises.
• Design and implementation of best-in-class tax control frameworks.
• Development of tax governance documentation and policies.
• Support with HMRC engagement and positioning.
• Ongoing risk monitoring and enhancement programs.

We combine deep technical expertise with a practical approach, helping businesses not only achieve a stronger BRR+ rating but also embed sustainable, value-driven tax governance.