HMRC requirement to publish a tax strategy

Produced by Tolley

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

  • HMRC requirement to publish a tax strategy
  • Businesses required to publish a tax strategy
  • Requirements
  • Contents
  • Non-compliance
  • Exceptions
  • Assessing the penalty
  • Appeals

HMRC requirement to publish a tax strategy

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.

HMRC announced in Summer Budget 2015 that it was going to require certain large businesses to publish their tax strategy. With effect from the first financial year beginning after Royal Assent to FA 2016, large businesses affected by this announcement are required to publish their strategy in respect of ‘UK taxation’ a term which includes, but is not limited to, VAT.

HMRC has yet to provide further details on certain aspects regarding the scope of the legislation, so this guidance note provides an overview of the requirements published to date.

HMRC has published some very high level guidance and a copy can be found via the following link: HMRC tax strategy publication high level guidance.

Businesses required to publish a tax strategy

The businesses who are required to publish their UK tax strategy are:

  1. qualifying UK group

  2. UK sub-group of a foreign qualifying group

  3. qualifying UK company, and

  4. qualifying UK partnership

Hereafter described as ‘qualifying businesses’. The above terms are described in detail in Finance Act 2016, Sch 19, Part 1 and in HMRC tax strategy publication high level guidance. However, broadly speaking they include UK businesses with a turnover, by reference to the previous financial year, of more than £200 million and / or with a balance sheet totalling more than £2 billion.

Please note that there is a provision to include MNEs subject to country by country reporting requirements with a global annual turnover of £568m, in the UK, either in their own right or if

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