Improving Tax Compliance – Have your say.


HMRC have just launched a consultation exercise on large business tax compliance. The intention of the consultation is to get views on a variety of proposed measures that are designed to:

“…drive further behavioural change in the large business population, embedding best practice in tax compliance in the population as a whole and equipping HMRC with additional tools to tackle the small number of large businesses which continue to engage in tax avoidance or aggressive tax planning, or resist full and open engagement with HMRC.”

The proposals include:

  • A legislative requirement for all large businesses to publish their tax strategy, enabling public scrutiny of their approach towards tax planning and tax compliance;
  • A voluntary ‘Code of Practice on Taxation for Large Business’, which sets out the behaviours which HMRC expects from its large business customers;
  • A narrowly targeted ‘Special Measures’ regime to tackle the small number of large businesses that persistently undertake aggressive tax planning, or refuse to engage with HMRC in an open and collaborative manner.


The measures are expected to mainly apply to the 2,100 largest and most complex businesses that are managed by HMRC’s Large Business Directorate.

The consultation document identifies that tax behaviour is increasing being determined at CEO and Board level rather than by a business’ tax department. In view of this one of the proposals is that there should be a named Board member with responsibility for owning and signing off tax strategy. This requirement would be similar to but separate from the current SAO requirements. 

Outlined within the document are suggestions as to what areas and issues should be covered in a published tax strategy. Also included is a draft Code of Practice providing a common set of guiding principles for positive tax compliance behaviour. In addition HMRC have set out their proposals for how they see the special measures regime operating. The document contains 22 consultation questions on the proposals and HMRC are seeking responses from all interested parties.

The consultation period runs from 22 July – 14 October 2015 and the full HMRC document can be viewed here.

Whilst greater tax transparency can be viewed as a good thing in light of recent public opinion and media coverage of those businesses not seen to be paying their fair share of tax, is it reasonable to place an increased compliance burden on all large businesses in an attempt to address the aggressive actions of a few?