HMRC — large business special measures regime

Produced by Tolley

The following Value Added Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • HMRC - large business special measures regime
  • Special measures regime
  • Businesses included within the scope
  • Conditions for entry into special measures
  • Condition 1 - behaviour
  • Condition 2 - arrangement
  • Condition 3 - significant level of tax at risk
  • Procedure for entering a business into special measures
  • Sanctions
  • Appeals

HMRC - large business special measures regime

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marked the end of the Brexit transition / implementation period entered into following the UK’s withdrawal from the EU. At this point in time, key transitional arrangements came to an end and significant changes began to take effect across the UK’s VAT and customs regime. This document contains guidance on subjects potentially impacted by these changes. Before continuing your research, see the Brexit — overview guidance note.

Finance Act 2016 introduced a special measures regime that is intended to tackle a small number of large businesses that are either persistently engaged in aggressive tax planning or refuse to engage with HMRC in an open and collaborative manner. HMRC has introduced special measures to deal with businesses with a history of uncooperative behaviour which causes a significant risk of loss of revenue to the Exchequer. The measure came into effect from the date of Royal Assent to Finance Bill 2016.

HMRC has published guidance on the scope of these special measures and it can be accessed via the following link: Special Measures Guidance. A summary of the announcements made have been provided below.

Special measures regime

Special measures will be applied to businesses with an ongoing history of entering into aggressive tax planning arrangements and / or refusing to engage with HMRC in an open and collaborative manner. Businesses that are likely to be entered into special measures will already be included in one of HMRC’s high risk management programmes. They will already been in regular conversations with their CRM and board to board meetings with HMRC.

HMRC will advise these types of businesses that they may be at risk of being put into special measures due to their ongoing conduct.

Affected businesses will be required to enter a 12-month improvement period which enables HMRC and the business

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