TEI comments on proposed UK tax strategy publication requirement.

• Position: Tax Executives Institute

On February 2, 2016, Tax Executives Institute submitted comments with HM Revenue & Customs, the revenue authority in the United Kingdom, regarding a proposal in the UK government's Finance Bill 2016 to require certain large businesses with UK operations to publish a UK tax strategy. The Institute's comments recommend clarifying the definition of a "UK sub-group" and how multinational businesses that are not headquartered in the United Kingdom can comply with the publication requirement. The comments were prepared under the aegis of TEI's European Direct Tax Committee, whose chair is Nick Hasenoehrl. Benjamin Shreck, TEI Tax Counsel, coordinated the development of the Institute's comments.

HM Revenue and Customs (HMRC) released a public consultation document entitled Improving Large Business Tax Compliance (the Consultation) on 22 July 2015. The Consultation solicited input from interested stakeholders regarding several measures intended to improve large business tax compliance in the United Kingdom and ended on 14 October 2015. A revised proposal to require qualifying large businesses or groups to publish a tax strategy as it relates to U.K. activities (the Tax Strategy Proposal or Proposal) was issued on 9 December 2015 under Clause 65 of Finance Bill 2016. On behalf of Tax Executives Institute, Inc. (TEI), I am pleased to submit comments on the Proposal.

TEI Background

TEI is the preeminent association of in-house tax professionals worldwide. Founded in 1944, today the organization has 56 chapters in Europe, North and South America, and Asia. TEI's approximately 7,000 professionals manage the tax affairs of over 2,800 of the leading companies across all industries around the world. TEI's members are accountants, lawyers, and other corporate and business employees responsible for the tax affairs of their employers in an executive, administrative, or managerial capacity. TEI is committed to promoting fair tax policy and the efficient administration of the tax laws, at all levels of government, seeking to achieve an effective yet dynamic balance between the policy objectives of tax authorities and the business objectives of multinational enterprises.

TEI's Europe, Middle East, and Africa (EMEA) Chapter was chartered in 1999 to address the advocacy, networking and educational needs of in-house tax professionals within those geographies. Our EMEA chapter has grown to more than 250 members since its chartering and has been actively involved in...