Requirement to publish your business strategy


Following the Royal Assent of Finance (No. 2) Bill 2016, large businesses will be required to publish, on the internet, their strategy in relation to UK tax.

Who is required to publish their tax strategy?


UK companies, partnerships, groups/sub-groups, and UK permanent establishments ("PEs") of foreign enterprises, where in the previous year turnover exceeded £200 million or the balance sheet total was over £2 billion. For UK groups/sub-groups, it is the aggregated turnover/balance sheet of all UK operations (including UK PEs).


UK entities which are part of a multi-national group, will also be required to publish their tax strategy regardless of the size of the UK operations, where the group is within the OECD country-by-country reporting framework (i.e. global turnover exceeds £750m).

When do they need to publish it?

When do they need to publish it?

The first strategy document should be published before the end of the first financial year commencing after 15 September 2016. After the first strategy, businesses must publish one each year, within 15 months of the last one being published.


The first businesses likely to be impacted are businesses with a 30 September 2017 year end, and the strategy document will need to be published before their year end.

What should it contain?


The tax strategy should explain the business’s tax arrangements. It does not need to include the amounts of tax paid or any commercially sensitive information.


The strategy document should include:


  • How the business manages tax risks;
  • Descriptions of key roles and responsibilities;
  • Systems and controls in place to manage tax risk;
  • Level of oversight of the company board and its involvement;
  • The business’s attitude to tax planning;
  • Compliance with tax regulations;
  • How the business works with HM Revenue & Customs ("HMRC") and meets its requirements.


The tax strategy can be a stand alone document or a dedicated section of a wider document (e.g. the annual report).

Failure to publish/publish incorrectly

Failure to publish on time, or publishing a tax strategy which does not comply with the legislation can result in penalties of:


  • Over 30 days – 6 months late – up to £7,500;
  • 6 – 12 months late – a further penalty of up to £7,500;
  • Over 12 months late – £7,500 every additional month.

What you need to do


The legislation is expected to apply to over 2,000 businesses. Many of the UK’s largest businesses already publish something on their approach to tax, but these will need to be reviewed to ensure they are compliant with the new legislation. For many other businesses this will be the first time they’ve been required to publish their tax strategy, although they may well have one in place.


Businesses need to consider whether they will fall within the new legislation. For very large UK businesses this is likely to be easy to determine, but for small UK entities which are part of a large multi-national group, this may be more difficult to establish.


If your business does fall within the legislation, you must review your business tax strategy to ensure it is compliant with the rules and re-draft it where necessary.


For more information please contact your usual Blick Rothenberg contact, or Genevieve Moore on +44 (0)20 7544 8815 or at