HMRC One to Many letter - Marginal Rate Relief 

HMRC have advised us that they have recently commenced a One to Many letter campaign directed at companies that HMRC have identified as having potentially not declared associated companies in their Corporation Tax returns and thus having potentially claimed higher marginal rate relief than they are entitled to. The letter sending process commenced on 21 July and will run through to 6 October.  

Two letters are being used. A copy of each of the letters is provided below.  Overall, the tone and framing of these letters are slightly different. In addition, one letter contains a section titled 'What happens next', which essentially discusses the potential for HMRC to open a compliance check if there is no response to the letter. HMRC have advised that two letter variants have been issued to test the impact of different framing and tone has on the engagement of recipients.  

Letter 1 - Check you’ve paid the right amount of Corporation Tax
Letter 2 - Please check you’ve paid the right amount of Corporation Tax