SM03050 | Special Measure: Behaviours: Overview and criteria

Special Measures applies to large businesses (SM02000) that exhibit persistently un-cooperative behaviours when engaging with HMRC.

There are no specific criteria regarding the type or frequency of unco-operative behaviours, what matters is a sustained pattern that delays or hinders HMRC’s ability to carry out its functions without evidence of improvement.

HMRC evaluates the conduct of the large business as a whole. A series of minor behavioural issues may collectively suggest a broader pattern of unco-operative behaviour.

For a large business (SM02000) to fall under Special Measures, all of the following criteria must be met:

• the business repeatedly demonstrates unco-operative behaviour

• some or all of these behaviours contribute to at least 2 significant unresolved tax risks (SM03200)

• there is a reasonable likelihood (SM03300) that similar unco-operative behaviours will occur again, potentially contributing to current or future tax risks