Press releases

Deloitte comments on draft legislation to require large business tax transparency

9 December 2015

The government today published its draft Finance Bill, which includes significant new tax governance requirements for larger businesses. The package of measures will apply to about 2,000 large businesses (those with annualised turnover in excess of £200 million or with balance sheet total in excess of £2 billion). They will come into force in 2016, after Royal Assent to the Finance Act, and include:

  • a new requirement that large businesses publish their tax strategies as they relate to or affect UK taxation; and
  • a special measures regime to tackle businesses that persistently engage in aggressive tax planning.

In the Autumn Statement a third proposal was announced – a cooperative compliance framework, which will be published shortly.

Bill Dodwell, head of Deloitte’s tax policy group, said:
“We welcome the new framework for co-operative compliance, which will refresh the approach that has been used successfully by HMRC’s Large Business Directorate over the last decade. The evidence from the global Forum on Tax Administration demonstrates that cooperative compliance achieves positive outcomes both for tax authorities and for business.”

“Many of the UK’s very largest businesses have responded to public calls for more information about taxation by publishing a tax policy, or tax strategy. It’s not so clear that the benefits of this will extend to 2,000 businesses, where the new requirement for publication may drive a more formulaic – and thus less informative – approach.”

Mark Kennedy, tax partner at Deloitte, added:
“Britain’s largest businesses want to comply with their statutory obligations and they expect to communicate their tax position meaningfully with key stakeholders, including HMRC. Our data shows that over 60% of the FTSE100 already comment publicly on their tax governance and in our experience the management of taxes is an increasingly important area of internal focus as compliance obligations grow. The benefits of publication by foreign-owned groups is less obvious, though, and it will be important to limit the administrative burden of this new requirement. We do welcome the changes made to the approach, following consultation.”


Notes to editors

The Finance Bill was published today, 9th December 2015. It sets out draft legislation for a wide range of tax measures.

The new tax governance requirements follow HM Revenue & Customs’ Improving Large Business Tax Compliance consultation, which took place over the summer of 2015.

The 2,000 largest businesses in the UK will be required to publish on their websites information about four areas of their UK tax strategy, covering:

  • the approach of the UK group to risk management and governance arrangements in relation to UK taxation;
  • the attitude of the group towards tax planning (so far as affecting UK taxation;
  • the level of risk in relation to UK taxation that the group is prepared to accept; and 
  • the approach of the group towards its dealings with HM Revenue and Customs

The government originally proposed that large businesses should be invited to sign up to a voluntary code of conduct, which has been replaced by the co-operative compliance framework. The Forum on Tax Administration published its most recent work on co-operative compliance in 2013, which is available here:

The Forum on Tax Administration (FTA) was created in 2002 and now comprises Tax Commissioners from 46 OECD and non-OECD countries, including every member of the G20. Its vision is to create a forum through which Commissioners can identify, discuss and influence relevant global trends and develop new ideas to enhance tax administration around the world. More details are at

About Deloitte
In this press release references to Deloitte are references to Deloitte LLP, which is among the country's leading professional services firms.

Deloitte LLP is the United Kingdom member firm of Deloitte Touche Tohmatsu Limited (“DTTL”), a UK private company limited by guarantee, whose member firms are legally separate and independent entities. Please see for a detailed description of the legal structure of DTTL and its member firms.

The information contained in this press release is correct at the time of going to press.

Member of Deloitte Touche Tohmatsu Limited.

Saskia Graepel
Deloitte LLP
0207 007 7264

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