TCRM8000 - Annex F: Regime Integrity Work

The concept of ‘regime integrity’ covers work that is carried out to ensure customers comply with tax regimes. This is achieved through Risk Assessment activities, mandatory work or activities driven by national or LBS campaigns or projects. New and emerging risks may be discussed with customers so that they are aware of the implications for their business. ‘Regime integrity' is not to be used as justification for any other activity outside those mentioned above.

Our main means of ensuring that our customers pay the tax and duties they are due to pay are:

• resourcing to risk, driven by our risk assessments of our customers and identifying and dealing with risks
• encouraging our customers to be open and transparent with us (e.g. by agreeing low risk relationships with some of them).

In addition to customer-focussed risk assessment and risk working regime integrity is secured by:

• discussions with customers to ensure they are aware of potentially significant new and emerging risks or ‘hotspots’, so that they can consider the implications for their business. The nature of the discussion will differ according to the type of relationship with the customer
• information-gathering on tax payments and other trends in sectors or more widely. For example, Sector Leaders will need to be able to discuss the trends in CT/VAT/PAYE etc receipts in their sector and the trends in significant claims (such as R&D claims, ‘Fleming’ claims, etc.). This means CRMs may be commissioned to obtain this information from their customers
• sector or national projects or campaigns commissioned to test gaps in our knowledge or to address particular tax risks or threats to a regime.

Regime integrity in low risk relationships

The principles we adopt in low risk relationships (TCRM9000) are described earlier in this guidance. The focus is on addressing risks as they arise, agreeing appropriate assurance by the customer for key areas of tax risk and trusting the customer’s responses to potential tax risks identified by national or sector projects or campaigns. CRMs should explain to Low Risk customers that there may be times when HMRC needs to initiate interactions; for example, where we need to find out how new legislation is working in practice, or where we have a new campaign (see above). CRMs should always discuss with their customers how to manage this type of work (within whatever discretion is available).