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Are you obliged to publish a Tax Strategy?

18 July 2018      Julia Ascott, Employment Taxes Specialist

Deloitte provided a session on tax governance and tax strategy at the recent tax conference, with some extremely useful input from Shona Blair of the University of Edinburgh. The University of Edinburgh is not legally obliged to publish a tax strategy, but interestingly it has taken the strategic decision to do so, given the size and complexity of the business. You are legally obliged to publish a tax strategy on a publicly accessible webpage if:

• Your university is incorporated via Companies House and your corporate group has a turnover of >£200m or assets of >£2bn; OR

• If the combined turnover of your subsidiary companies (excluding the university, if not incorporated via Companies House) is >£200m or the combined assets of your subsidiary companies are worth >£2bn.

You can find HMRC’s guidance on tax strategies here, which is helpful in setting out what they expect a strategy to include, albeit it is misleading in terms of who is obliged to publish one (failing to point out the Companies House criterion). A number of universities have already published their tax strategies - you can view the University of Edinburgh’s tax strategy here. The slides from the conference session are available here.

Should you have a published tax strategy even if not obliged to? That’s up to individual universities to decide, given their size, complexity, and general governance, but: “HMRC will expect any large organisation to be able to articulate how it manages its tax affairs.” (Deloitte). If you do have an obligation to publish a strategy, it must be published by 31 July.



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