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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