Publishing a tax strategy for large businesses

UK groups, sub groups, companies and partnerships must publish a tax strategy online each financial year if, in the previous financial year, their UK turnover was above £200 million or their UK balance sheet was over £2 billion, or if they belong to a multinational group with global turnover over 750 million euros. The strategy must cover four set topics, stay free to view until the next one is published, and be refreshed at least every 15 months. Failing to publish a compliant strategy costs £7,500, with further £7,500 penalties if the failure continues.

Where does the requirement come from?

The duty is in Part 2 of Schedule 19 to the Finance Act 2016. Paragraph 16 deals with qualifying UK groups, paragraph 19 with UK sub groups of foreign groups, paragraph 22 with individual qualifying companies and paragraph 25 applies the company rules to qualifying partnerships. HMRC’s guidance, Publish your large business tax strategy, explains how it applies the law in practice.

The requirement applies for financial years starting after 15 September 2016. The strategy is public and sits alongside the senior accounting officer rules, which deal with internal tax accounting arrangements and are reported privately to HMRC.

Which businesses must publish a tax strategy?

According to HMRC’s guidance, a UK group, sub group, company or partnership must publish a strategy if in its previous financial year it had turnover above £200 million, a balance sheet over £2 billion, or both. Alternatively, UK companies or groups that are part of a multinational enterprise (MNE) group meeting the OECD country by country reporting threshold of global turnover over 750 million euros must publish.

HMRC describes these tests as mutually exclusive. A UK company in an MNE group with global turnover under 750 million euros does not need to publish, even if its own turnover exceeds £200 million.

• UK groups. The UK head of the group is responsible for a single group strategy covering all members.
• Foreign groups with UK sub groups. The head of each UK sub group is responsible for a strategy covering all UK companies and UK branches in that sub group. A foreign group can have more than one UK sub group.
• UK sister companies. Where a foreign parent owns a UK subsidiary directly, with no UK intermediate parent, each such UK company must publish its own strategy, even if it would not be large enough on its own.
• Standalone companies. A qualifying company that is not in a UK group or sub group publishes its own strategy.
• Partnerships. General partnerships, limited partnerships and UK limited liability partnerships can qualify. The nominated partner is responsible.

Open ended investment companies and investment trusts do not need to publish. Where group companies have different year ends, HMRC says to aggregate each member’s latest financial year ending before the end of the head company’s year and not to pro rate overlapping periods.

What must the strategy contain?

Paragraph 17(1) requires a group tax strategy to set out four things, and paragraph 23 applies the same list to a company:

1. the approach to risk management and governance arrangements in relation to UK taxation;
2. the attitude towards tax planning, so far as it affects UK taxation;
3. the level of risk in relation to UK taxation that the business is prepared to accept;
4. the approach towards dealings with HMRC.

HMRC’s guidance expands on each heading. Under risk management it suggests describing the governance framework, the level of board oversight, and the key roles, systems and controls. Under tax planning it suggests any code of conduct, what influences planning decisions and why external advice might be sought. Under risk appetite it asks for the levels of risk accepted and how they are measured internally. Under dealings with HMRC it asks how the business works transparently with HMRC on current, future and past tax risks, even if HMRC already knows this.

HMRC also says the strategy should be approved by the board. It does not need to include the amounts of tax paid or commercially sensitive information.

One detail is easy to miss. Under paragraph 17(4), publishing the information only counts if the publishing company makes clear, in a way readily apparent to anyone reading online, that it regards the publication as complying with the duty for the current financial year. HMRC’s guidance puts this as including details of the paragraph of the legislation the strategy complies with.

Where and when must it be published?

The strategy must be published on the internet and be accessible free of charge. It can be a separate document or a self contained part of a wider document such as the annual report. HMRC says a member of the public should be able to find it easily by browsing the business’s website or searching online. If the entity has no website, it can use the foreign parent’s website, another subsidiary’s website, or another site agreed with HMRC.

The timing rules are:

• The strategy for a financial year must be published before the end of that financial year.
• If the business also qualified the year before, the new strategy must be published no more than 15 months after the previous one was published.
• The published strategy must remain freely accessible until the next year’s strategy is published.
• If the business stops qualifying, HMRC’s guidance says the last strategy must remain accessible for at least a year from the date it was published.

An unchanged strategy must still be republished in each financial year. The 15 month rule bites when a year end is extended: HMRC’s own example shows a business that published on 20 March 2018 and then lengthened its next financial year to 30 September 2019, which had to publish its second strategy by 20 June 2019. A change of year end, covered in our guide to changing a company’s year end, should therefore trigger a check of the publication date.

What are the penalties for not publishing?

The responsible entity (the head of the UK group or sub group, the company, or for partnerships the partnership through its nominated partner) is liable to a £7,500 penalty if it fails to publish a strategy that complies with the requirements or fails to keep a published strategy accessible. If no compliant strategy is published within six months after the last day it could have been, a further £7,500 penalty applies, followed by another £7,500 at the end of each subsequent month in which none is published (paragraphs 18, 21 and 24).

HMRC’s guidance says that before charging a penalty it will issue a non statutory warning notice giving 30 days to publish a compliant strategy, and that no penalty will be charged if one is published within that time. HMRC has said it intends to review whether to keep issuing these notices, so they should not be relied on.

Under paragraph 28 there is no penalty if the business has a reasonable excuse. Relying on someone else is not a reasonable excuse unless reasonable care was taken, and a UK group or sub group cannot rely on another member of the same group. HMRC must assess a penalty within six months of the failure coming to an officer’s attention and no later than six years after the end of the financial year in which the strategy should have been published. An appeal must be made in writing within 30 days of the assessment.

How does it work in practice? An illustration

Illustration only. A UK parent company with a 31 December year end has turnover of £160 million for 2025. Its only subsidiary, a UK company with a 31 March year end, had turnover of £60 million for its year to 31 March 2025. Neither is part of a multinational group.

• Aggregated turnover for the group’s 2025 financial year is £220 million, so the group qualifies for its financial year to 31 December 2026.
• The parent, as head of the UK group, must make sure a group strategy covering both companies is published online before 31 December 2026, stating that it is published to comply with paragraph 16(2) of Schedule 19 for that year.
• If the group still qualifies the following year and its 2026 strategy went online on 1 September 2026, the 2027 strategy must be published by 31 December 2027 and in any case within 15 months of 1 September 2026, so by 1 December 2027.
• If nothing had been published by 31 December 2026, a £7,500 penalty would be in point, and a second £7,500 would follow if it was still missing six months later.

What are the common mistakes?

• Omitting the statement that the publication is made to comply with the legislation for the current year, which on a strict reading means the duty has not been met.
• Letting the old strategy disappear during a website rebuild before the new one is live.
• Assuming an overseas parent’s global tax policy covers UK sister companies or sub groups when it does not say so. HMRC will accept one strategy for several UK entities only if it clearly identifies the entities it covers.
• Rolling the same document forward without republishing it in the new financial year.

Businesses describing their attitude to tax planning often find it useful to set out where they draw the line between legitimate planning and tax avoidance. Large businesses that publish a strategy will usually also need to consider whether any positions taken in their returns must be reported under the uncertain tax treatment rules.

If HMRC opens a check into your return, tax investigation insurance pays your accountant’s fees. Solar Protect cover pays up to £100,000 with no excess; it never pays tax, interest or penalties. Read how our cover works or get a quote.

Related Accountapedia entries

• The Wates Principles for large private companies
• Transfer pricing documentation requirements
• Country by country reporting
• Quarterly instalment payments for large companies
• Group payment arrangements for corporation tax

Sources

• legislation.gov.uk: Act 2016 c. 24, schedule 19
• GOV.UK: Large businesses publish your tax strategy

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.