Tax strategy support

The tax strategy document is an important compliance requirement for large businesses but also creates an opportunity to manage tax risk and reputation.
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A published tax strategy is a public document outlining a company’s, partnership’s or group’s approach and attitude to UK tax planning, UK tax risk management policies and internal governance, and how it manages its relationship with HMRC. It is important that the tax strategy reflects the organisation’s policies and values and that the organisation can support the statements made with evidence if required.

The requirement to publish tax strategies aimed to put reputational pressure on large businesses to pursue less aggressive tax planning arrangements. There is still significant public interest in businesses’ taxation, and the publication of a tax strategy is an opportunity to help shape your company’s reputation.

For relevant businesses, the tax strategy must be approved by its board of directors, published online, and be accessible free of charge to the general public. The strategy should be reviewed and re-published annually.

It is the responsibility of each business to establish whether or not they meet the requirements for publishing a tax strategy.

Help with your tax strategy

We support businesses in various ways:

  • Assessing publication requirements

    Determining whether or not your business needs to publish a tax strategy is not always straightforward, particularly for large multinational groups with complex structures. We help businesses assess their tax strategy obligations and the applicable deadlines

  • Preparation and review

    For businesses publishing a tax strategy for the first time, we help draft the relevant documents, ensuring they are fully compliant and aligned with the values of your business. For businesses re-publishing a tax strategy, we can review your documentation annually, ensuring any changes in tax legislation, HMRC guidance or your business activities are reflected in the strategy.

Get in touch

Speak to our experts today about how we can help you protect and enhance your reputation through your published tax strategy document. 

Get in touch

Frequently asked questions about tax strategy

UK companies, partnerships and groups are required to publish a tax strategy, if, in the prior financial year, the entity or group had one of the following:

  • turnover of more than £200 million
  • a balance sheet total (i.e. gross assets) over £2 billion

UK companies and groups must also publish a tax strategy if they are part of a multinational enterprise (MNE) group with a global turnover in excess of €750 million.

If you first meet the conditions in the previous financial year, your tax strategy must be published before the end of the current financial year.

Once a strategy has been published for the first time, a new one must be published by the earlier of 15 months from the date on which the strategy was first published or within the next financial year.

As well as stating the financial year to which it relates and details of the applicable legislation, your tax strategy should include the following information:

  • how your business manages UK tax risks
  • your business’s attitude to tax planning
  • the level of risk your business is prepared to accept for UK taxation
  • how your business works with HMRC
  • any other relevant information relating to taxation

Your tax strategy should be approved by the board of directors and, importantly, be in line with your business’s overall strategy and operation.

It does not need to include the amounts of taxes and duties paid or any information that might be commercially sensitive.

Penalties may be levied if your business meets the requirements to publish a tax strategy but fails to do so, the published strategy does not include all relevant information, or the tax strategy isn’t made available for free for the appropriate period.

Potential penalties are as follows:

  • a £7,500 penalty for not publishing a compliant tax strategy
  • a second £7,500 penalty if the compliant tax strategy has not been published six months after it should have been
  • another £7,500 penalty for each following month until the compliant tax strategy is published

HMRC should issue a non-statutory warning notice to publish a compliant tax strategy within 30 days, and a penalty will not be levied if a compliant document is published during this period.