On 29 September 2026, HMRC released updated guidance CC/FS1c covering compliance checks for large and complex businesses. This publication forms part of HMRC’s ongoing transparency initiative to clarify the compliance check process for multinational enterprises and large corporate groups. The guidance outlines the framework HMRC uses to select businesses for review, the powers available to officers during checks, and the rights and obligations of taxpayers throughout the process. It addresses specific considerations for complex group structures, cross-border transactions, and transfer pricing arrangements. The update reflects recent legislative changes and case law developments, providing certainty for businesses managing UK tax risk.
Key Takeaways
- Enhanced Transparency on Selection Criteria: The guidance details HMRC’s risk-based approach to selecting large businesses for compliance checks, including the use of data analytics and sector-specific risk profiles, enabling proactive tax governance.
- Clarified Officer Powers and Taxpayer Rights: Explicit enumeration of HMRC’s information and inspection powers under FA 2008 Schedule 36, balanced with taxpayer safeguards including the right to appeal and standards for officer conduct.
- Specific Guidance for Complex Structures: Tailored procedures for groups with cross-border operations, transfer pricing exposure, and hybrid mismatch arrangements, aligning with BEPS Action Plan outcomes and UK domestic anti-avoidance rules.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement