Corporation Tax

Sanctions for persistently uncooperative large businesses

Produced by Tolley
  • 19 May 2022 08:21

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

  • Sanctions for persistently uncooperative large businesses
  • Introduction
  • Definitions
  • Notices
  • Warning notice
  • Special measures notice
  • Other situations in which a special measures notice may be issued
  • Confirmation notice
  • Increased penalties for errors
  • ‘Naming and shaming’
  • More...

Sanctions for persistently uncooperative large businesses


Following a period of consultation on ‘Improving Large Business Tax Compliance’ during 2015, Finance Act 2016, s 161 and Sch 19, Part 3 introduce a regime to counter persistently uncooperative behaviour from large businesses.

The rules apply to large UK groups but are also extended to include large UK sub-groups, large companies and large partnerships by FA 2016, Sch 19, paras 50–52. For the sake of brevity, this guidance note mainly refers to the rules in the context of large UK groups.

The Government hopes that a targeted ‘special measures’ regime will tackle those large businesses who persistently pursue aggressive tax planning or refuse to engage in an open and collaborative way with HMRC. In parallel, there is now a legislative requirement for large businesses to publish their tax strategy, see the Publication of tax strategies by large businesses guidance note for the detailed provisions enacted in this area.

Additionally, from 1 April 2022, large businesses will need to notify HMRC when they take an uncertain tax position in their returns for VAT, corporation tax or income

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