Tax Strategy Statement Template (UK Finance Act 2016 Schedule 19)

Tax Strategy Statement: [Group or company name] FY[YYYY]

Published tax strategy for a large business, with the internal preparation, approval and publication record behind it. Based on the UK requirement in Finance Act 2016, Schedule 19 (publication of a tax strategy by qualifying groups, sub-groups, companies and partnerships) and the HMRC guidance "Large businesses: publish your tax strategy" (last updated 2024-07-30), and adaptable as a voluntary statement in other countries. Sections 2 to 7 are the text to publish; sections 1, 8 and 9 are internal. Replace every [bracketed] value and every row marked Example. This is a document format, not tax, legal, accounting or financial advice. Obtain the legislation and current HMRC guidance for the normative text.

Document control

Approvals

Revision history

Contents

• 1. Applicability and statutory basis (internal)
• 2. Introduction and scope (published)
• 3. Approach to risk management and governance (published)
• 4. Attitude towards tax planning (published)
• 5. Level of tax risk accepted (published)
• 6. Working with HMRC (published)
• 7. Other tax information (published, optional)
• 8. Using the template outside the UK (internal)
• 9. Preparation, approval and publication record (internal)
• 10. Glossary and references
• Standard and licence note

1. Applicability and statutory basis (internal)

Schedule 19 applies to UK groups, UK sub-groups, UK companies and UK partnerships that meet the qualifying conditions. Under HMRC guidance, the conditions are met in one of two separate ways:

1. The UK business had turnover above GBP 200 million, or a balance sheet total above GBP 2 billion, in the previous financial year.
2. The UK business is part of a multinational group that must file a country-by-country report because its global turnover is above EUR 750 million.

The tests do not combine. A UK company in a multinational group below the EUR 750m threshold does not publish under the second test, even if its own UK turnover is above GBP 200m, according to the HMRC guidance; check the current guidance for this point. A UK company or sub-group does not need its own strategy if a strategy published by an entity higher in the group covers it. Open-ended investment companies and investment trusts are excluded.

1.1 Statutory paragraph

The published strategy must say which paragraph of Schedule 19 it is published under. Confirm the correct paragraph with the current text on legislation.gov.uk and with an adviser.

Example: Ostrander UK Ltd is the only UK entity of a group headed in the Netherlands. The draft treats it as a UK sub-group and cites paragraph 19(2). Whether a single UK company of a foreign-headed group publishes as a UK sub-group or as a qualifying company could not be confirmed against the legislation text for this template, so the head of tax confirms the paragraph with the UK adviser before publication.

1.2 Timing

Strategies are required for each financial year beginning after 2016-09-15 in which the conditions are met. The first strategy must be published before the end of the financial year in which the business first qualifies (based on the previous year's figures). Later strategies must be published in the following financial year, and no more than 15 months after the previous one, whichever is earlier. The latest strategy must stay freely available online until the next one replaces it, and it must be republished every year, even if nothing changes.

Example: The group's consolidated revenue first reached EUR 750m in FY2023 (EUR 755m), so Ostrander UK Ltd first qualified for FY2024 and published its first strategy in 2024. It published the FY2025 strategy on 2025-11-28. The FY2026 strategy must be published by the earlier of the end of FY2026 (2026-12-31) and 15 months after the previous publication (2027-02-28), so the deadline is 2026-12-31.

1.3 Penalties

HMRC guidance states a penalty of GBP 7,500 for failure to publish, a further GBP 7,500 if the strategy is still not published six months after the due date, and GBP 7,500 for each later month until it is published. HMRC normally issues a warning notice first, and no penalty arises if a compliant strategy is published within 30 days of that notice. Penalties can also apply to an incomplete strategy or one that is not kept freely available. Treat the deadline as a hard control date in the tax calendar.

2. Introduction and scope (published)

[Publishing entity] is part of [Group name], [one-sentence description of the business]. This document sets out the tax strategy of [the UK group / the UK sub-group / the company] for the financial year ending [YYYY-MM-DD]. It applies to [list of UK entities] and remains in force until replaced.

This strategy is published in accordance with paragraph [19(2)] of Schedule 19 to the Finance Act 2016 and was approved by the board of [Publishing entity] on [YYYY-MM-DD].

Example: Ostrander UK Ltd is the UK subsidiary of Ostrander Group N.V., a software and commerce business that serves retailers in Europe, North America and Asia. This document sets out the tax strategy of Ostrander UK Ltd for the financial year ending 2026-12-31. It applies to Ostrander UK Ltd, the only UK entity of the group, and remains in force until the FY2027 strategy is published. This strategy is published in accordance with paragraph 19(2) of Schedule 19 to the Finance Act 2016 and was approved by the board of Ostrander UK Ltd on 2026-11-20.

3. Approach to risk management and governance (published)

Describe the people, processes and controls that manage UK tax risk. Name roles, not individuals, so the text stays accurate when people change.

Example (published text): The board of Ostrander UK Ltd is responsible for the company's tax affairs and approves this strategy each year. Day-to-day management sits with the group head of tax, who reports to the group Chief Financial Officer, supported by the UK finance team and external advisers where specialist knowledge is needed. Tax responsibilities are written into the group delegation of authority, so that decisions with significant tax effects, such as reorganisations, financing and new business models, are reviewed by the tax team before they are approved.

We manage tax risk within the group risk management framework. Tax risks are recorded in the group risk register with an owner, a rating and a response, and the group head of tax reports significant tax risks to the audit committee at least twice a year. Key tax processes, including VAT returns, corporation tax computations, payroll taxes and transfer pricing, are covered by documented controls that are reviewed each year. We use specialist software for indirect tax and keep our systems in line with HMRC digital requirements.

We do not tolerate tax evasion or its facilitation by anyone acting on our behalf. We maintain procedures to prevent the facilitation of tax evasion under Part 3 of the Criminal Finances Act 2017, train relevant staff, and give employees and contractors a confidential route to raise concerns through our whistleblowing channel.

4. Attitude towards tax planning (published)

Explain the business's position on tax planning in specific terms: what it does, what it does not do, and how it decides.

Example (published text): We structure our business to support its commercial activities, and we pay tax where we create value. We use tax reliefs and incentives that the government offers, such as research and development relief, in the way Parliament intended and when we carry out the qualifying activity. We do not enter into arrangements whose main purpose is to obtain a tax advantage, and we do not use artificial structures or transactions without commercial substance.

Transactions between Ostrander companies follow the arm's length principle, in line with the OECD Transfer Pricing Guidelines and UK law. We document our transfer pricing each year. Where the tax treatment of a significant transaction is uncertain, we take external advice and may discuss it with HMRC before we act.

As part of a group with consolidated revenue above EUR 750m, we are within the scope of the global minimum tax rules (Pillar Two), which the UK applies through the multinational top-up tax and the domestic top-up tax. We plan on the basis that the group's profits are taxed at an effective rate of at least 15% in each country where it operates.

5. Level of tax risk accepted (published)

State the risk appetite in words and give the reader a sense of how it works in practice. Link it to the group risk appetite where one exists (see Risk Appetite Statement, finance/risk-appetite-statement).

Example (published text): Our appetite for UK tax risk is low. Tax law is complex and some positions require judgement, so we cannot remove all risk. Where a position is uncertain, we aim to take a view that we believe is more likely than not to be correct, we document our reasoning and we disclose the position to HMRC where appropriate.

We escalate to the group Chief Financial Officer any tax position with a potential effect above GBP [500,000] or any position that could affect our reputation, regardless of size. We will not adopt a position that we expect HMRC would successfully challenge, and we do not participate in schemes marketed mainly to save tax.

6. Working with HMRC (published)

Describe the relationship with HMRC honestly. Mention the customer compliance manager relationship where one exists, how errors are corrected, and how disagreements are resolved.

Example (published text): We aim to have an open, honest and cooperative relationship with HMRC. We file returns and pay taxes on time, and we correct and disclose errors promptly when we find them. Where we have a significant transaction or an uncertain position, we discuss it with HMRC in real time where practical, so that issues are resolved before returns are filed.

When we disagree with HMRC, we try to resolve the matter through discussion. If we cannot agree, we may use the formal routes available, including alternative dispute resolution, internal review and the tribunals. We expect the same professional and respectful approach from HMRC as we aim to provide, in line with the HMRC Charter.

7. Other tax information (published, optional)

Schedule 19 allows the strategy to include other relevant information. Many businesses add a short description of the taxes they pay and collect, their transparency commitments, and links to other reports. Make sure any numbers reconcile to the audited accounts and the income tax note (finance/income-tax-provision).

Example (published text): In the UK, Ostrander UK Ltd pays corporation tax, employer national insurance contributions and business rates, and collects VAT and employee taxes on behalf of HMRC. The group publishes a description of its tax governance in its annual report, and its tax principles apply to every company in the group, not only to the UK.

8. Using the template outside the UK (internal)

The four content areas of a UK tax strategy (risk management and governance, attitude to tax planning, level of risk, and dealings with the tax authority) are a sound outline for any published tax statement. Adapt the authority name and add local requirements.

When the group publishes a single global statement, keep a short UK section that names the UK entities, the financial year and the Schedule 19 paragraph, so the UK legal requirements are met in one place.

9. Preparation, approval and publication record (internal)

Publish the strategy on the business's own website where possible, as a standalone page or a clearly labelled part of a larger document, so a reader can find it through the site or a web search. If the UK entity has no website, HMRC guidance allows publication on a parent's or another group company's site, or another site agreed with HMRC. Keep the previous year's version in the archive, and keep the current one online until the next one replaces it.

9.1 Annual review questions

Use these questions in the annual review before approval:

1. Did anything change in the business (new products, acquisitions, restructuring, new countries) that changes the tax risk profile?
2. Did UK tax law or HMRC practice change in a way the strategy should reflect, for example the global minimum tax or new digital filing rules?
3. Does the actual behaviour of the business during the year match the published statements, including any disputes with HMRC?
4. Are the risk appetite and escalation thresholds still right?
5. Is the statutory paragraph and financial year correct, and is the board approval date recorded?

Where the UK business also meets the senior accounting officer conditions in Finance Act 2009, Schedule 46, align the tax control evidence used for that certificate with section 3, so that the published description and the internal controls tell the same story.

10. Glossary and references

10.1 Glossary

10.2 References

Standard and licence note

Based on Finance Act 2016, Schedule 19, and the HMRC guidance "Large businesses: publish your tax strategy" (last updated 2024-07-30), which contain public sector information licensed under the Open Government Licence v3.0. The other laws, codes and standards in section 8 and the references are cited by name only. The template text and the example strategy wording are original and written for this collection; they are not HMRC wording and do not represent HMRC's views. Ostrander Group N.V., Ostrander UK Ltd and every figure are fictional. Check the current legislation on legislation.gov.uk and the current HMRC guidance before publishing. Template licence: MIT.