˾ҹ

What activity is targeted?

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

What activity is targeted?

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

Introduction

A regime is in place which seeks to counter persistently uncooperative behaviour from large businesses who pursue aggressive tax planning or refuse to engage in an open and collaborative way with HMRC. The rules apply to large UK groups, large UK sub-groups, large companies and large partnerships with turnover in excess of £200 million and total assets in excess of £2 billion. For the sake of brevity, this guidance note mainly refers to the rules in the context of large UK groups.

In parallel, there is also a legislative requirement for large businesses to publish their tax strategy, making it available for public scrutiny. See the Publication of tax strategies by large businesses guidance note for further details.

Additionally, from 1 April 2022, large businesses must notify HMRC when they take an uncertain tax position in their returns for VAT, corporation tax or income tax (including PAYE). This is explained further in the Notification of uncertain tax treatment ― overview guidance note.

A UK group falls within the rules if it has persistently engaged in uncooperative

Access this article and thousands of others like it
free for 7 days with a trial of Tolley+™ Guidance.

Powered by
  • 10 Nov 2023 08:02

Popular Articles

Residential property and capital allowances

Residential property and capital allowancesResidential property ― plant and machinery allowancesOrdinary residential property does not, and never has, qualified for capital allowances. as CAA 2001, s 35 denies plant allowances for expenditure incurred in providing plant or machinery for use in a

14 Jul 2020 17:14 | Produced by Tolley in association with Martin Wilson and Steven Bone Read more Read more

Timing of disposal for capital gains tax

Timing of disposal for capital gains taxDate of disposalThe date of the disposal determines the period in which the gain is subject to capital gains tax (CGT). When the rates of CGT change, the determination of the date of disposal can also affect the rate of CGT that applies to the gain.See the

14 Jul 2020 13:50 | Produced by Tolley Read more Read more

Payroll record keeping

Payroll record keepingUnder SI 2003/2682, reg 97, “...an employer must keep, for not less than 3 years after the end of the tax year to which they relate, all PAYE records which are not required to be sent to [HMRC]...”. Reasons for keeping the records include:•being able to calculate tax and

14 Jul 2020 12:52 | Produced by Tolley in association with Ian Holloway Read more Read more