15 April 2016

UK introduces large business special measures regime

The UK's Finance Bill 2016 introduces a special measures regime, said to be aimed at tackling the small number of large businesses that engage in aggressive tax planning, or refuse to engage with HM Revenue & Customs (HMRC) in an open and collaborative manner. The legislation refers in its headings to "large groups" but potentially brings all UK groups, UK sub-groups, UK companies (which for this purpose appears to include UK permanent establishments of non-UK resident entities) and "UK partnerships" within the scope of the measures.

A Tax Alert prepared by Ernst & Young UK, and attached below, provides additional details.

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ATTACHMENT

Document ID: 2016-0696