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HMRC Large Business Consultation

29 July 2015      Amanda Darley, Head of Operations and Engagement

HMRC has launched a consultation on Improving Large Business Tax Compliance which could affect universities.

It looks at ways to encourage large businesses to adopt a low-risk approach to tax compliance and to embed best practice. It's not clear whether or not the proposals would apply to universities as the document refers to " an objective threshold which qualifies a business as in scope" suggesting "the measures might apply to all businesses who have a turnover of more than £200 million and/or a relevant balance sheet total of more than £2 billion". This would clearly include many universities.

However, the document goes on to state that this is "the same threshold set for the Senior Accounting Officer (SAO) requirement", except that the SAO regime only applies to companies incorporated under the Companies Act, which means most universities are not affected. However, this consultation merely refers to "businesses", which could well include universities.

Some of the proposals include:

  • An obligation to publish a tax strategy;
  • Introducing a voluntary 'Code of Practice on Taxation for Large Business';
  • Introducing a 'special measures' regime to target large business which "persist in undertaking persistent and aggressive tax planning and/or persistently refuse to engage with HMRC in a collaborative and transparent way".

BUFDG would like to submit a response to this consultation, based on members' views. We have created a template for responses which includes all the questions from the consultation document which you can download here, then complete and send to Amanda. You do not have to answer all the questions. Please provide your responses by 30th September.



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