Michaela Merz

UK – compulsory publication of tax strategy for large businesses required

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227673_web_r_by_fikomiwi_pixelio-deThe compulsory publication of tax strategy for large business was introduced by the Finance (No. 2) Bill 2016 and it received Royal Assent on 15 September 2016, so it is now an Act of Parliament (Finance Act 2016 c.24). The relevant provisions for tax strategy are included in Schedule 19 of the Act, attached below at the very end of this blogpost.

Company, partnership, group or sub-group, having either turnover above £200 million or balance sheet over £2 billion are obliged to publish their tax strategy. The threshold for groups and sub-groups is the combined totals of all the relevant bodies. Companies not headed by a UK company not meeting the threshold in its own right may still qualify if they achieve the OECD’s CBCR framework threshold of a global turnover of more than €750 million.

The strategy does not need to be sent to HRMC but has to be published. The strategy will be seen as ‘published’ when it is first put on the internet. After the first strategy was published, updated publication has to be done within 15 months of the last one being published.

The published tax strategy has to explain current business’s tax arrangements. Amounts of tax paid or commercially sensitive information do not need to be included. If separate UK strategy is available it should be published as well. Further required are information how tax risk is linked to the business’s size, complexity and any changes in the business.

Information about management business’s tax risk, a high level description of key roles and their responsibilities, information on the systems and controls in place to manage tax risk and details on the levels of oversight of business’s board and its involvement are required as well. Further required is code of conduct if available as well as explanation why external tax advice is used, if any. Additionally details about tax planning motives have to be included.

For further details please see the following useful links and attachment.





Please avoid copy paste from the website of your competitors. Use the opportunity to show, that the tax function within your company delivers value and manage the tax risk. Do not forget to involve your management board and ask your board of directors or at least the audit committee to formally approve your strategy.

Only then it becomes valuable piece for your organisation. To draft tax strategy is not an exercise, which can be done just within a day. So if you are serious about it, take into account that a number of discussions may be needed until you will be able to finalize the tax strategy. If you struggle with how to do it, I would with great pleasure support you as a sparing partner or coach to achieve the best result internally as well as for needs of HMRS. Tax strategy is my passion.

Image source:  fikomiwi  / pixelio.de

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