# 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.

<!--
Guidance: How to use this template
- Use it each financial year in which the business meets the UK
  qualifying conditions, or when the board decides to publish a
  voluntary tax strategy elsewhere.
- Fill section 1 first: it records why the business must publish, under
  which paragraph of Schedule 19, for which financial year and by when.
  Then draft sections 2 to 7 in plain language, have the board (or its
  delegate) approve them, and publish them on the website.
- Write for a reader outside the business: investors, journalists,
  employees and HMRC. Short, specific statements beat long legal text.
  Do not include amounts of tax paid or commercially sensitive
  information unless the business chooses to.
- The worked example is the fictional Ostrander Group N.V.: an IFRS
  reporter with functional currency EUR, calendar financial year,
  parent OST-NL in the Netherlands, subsidiaries in Germany, the UK, the
  US and Vietnam. Its UK subsidiary, Ostrander UK Ltd (OST-UK), has UK
  turnover below GBP 200m but belongs to a multinational group with
  consolidated revenue above EUR 750m (EUR 755m in FY2023, EUR 760m in
  FY2024, EUR 820m in FY2025, EUR 900m in FY2026), so it must publish
  under the multinational test. The same group and figures appear in
  Pillar Two GloBE Readiness Assessment
  (`finance/pillar-two-globe-readiness`), the Country-by-Country Report
  Workpaper (`finance/country-by-country-report-workpaper`) and the
  transfer pricing templates.
- Related documents: Income Tax Provision (`finance/income-tax-provision`),
  Transfer Pricing Master File (`finance/transfer-pricing-master-file`),
  Transfer Pricing Local File (`finance/transfer-pricing-local-file`),
  Country-by-Country Report Workpaper
  (`finance/country-by-country-report-workpaper`), Delegation of
  Authority Matrix (`finance/delegation-of-authority-matrix`), Risk
  Appetite Statement (`finance/risk-appetite-statement`), Risk Register
  (`compliance/risk-register`), Whistleblowing Policy
  (`compliance/whistleblowing-policy`).
-->

## Document control

<!-- Guidance: The published strategy must be approved and republished every year, even if unchanged. Keep this table internal; publish only sections 2 to 7. Pitfall: a website page with no date or year, so nobody can show which strategy was in force when. -->

| Field | Value |
|---|---|
| Document ID | [TAXSTRAT-FY2026] |
| Publishing entity | [Head of UK group / UK sub-group / UK company / partnership] *Example:* Ostrander UK Ltd (UK), for itself as a UK sub-group of Ostrander Group N.V. (Netherlands) |
| Financial year covered | [YYYY-MM-DD to YYYY-MM-DD] *Example:* 2026-01-01 to 2026-12-31 |
| Statutory basis | [Finance Act 2016, Schedule 19, paragraph 16(2) / 19(2) / 22(2) / 25(1)] |
| Publication deadline | [YYYY-MM-DD] *Example:* 2026-12-31 |
| Publication URL | [https://example.com/tax-strategy] |
| Version | [0.1] |
| Status | [Draft / Approved / Published / Superseded] |
| Owner | [@head-of-tax] |
| Approvers/reviewers | [@cfo], [@board-of-directors], [@uk-director] |
| Board approval date | YYYY-MM-DD |
| Last updated | YYYY-MM-DD |
| Classification | [Public once published; drafts internal] |
| Related documents | [Tax risk register], [Tax control framework], [Transfer pricing documentation] |

### Approvals

| Role | Name | Decision | Date |
|---|---|---|---|
| Head of tax | [@name] | [Recommend] | YYYY-MM-DD |
| Chief Financial Officer | [@name] | [Recommend] | YYYY-MM-DD |
| Board of the publishing entity (or board of the parent where it approves for the group) | [@chair] | [Approve] | YYYY-MM-DD |

### Revision history

| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | Draft based on prior-year strategy |
| 0.2 | YYYY-MM-DD | [@name] | *Example:* Added Pillar Two and digital tax administration paragraphs |
| 1.0 | YYYY-MM-DD | [@name] | Approved by the board and published |

## Contents

- [1. Applicability and statutory basis (internal)](#1-applicability-and-statutory-basis-internal)
- [2. Introduction and scope (published)](#2-introduction-and-scope-published)
- [3. Approach to risk management and governance (published)](#3-approach-to-risk-management-and-governance-published)
- [4. Attitude towards tax planning (published)](#4-attitude-towards-tax-planning-published)
- [5. Level of tax risk accepted (published)](#5-level-of-tax-risk-accepted-published)
- [6. Working with HMRC (published)](#6-working-with-hmrc-published)
- [7. Other tax information (published, optional)](#7-other-tax-information-published-optional)
- [8. Using the template outside the UK (internal)](#8-using-the-template-outside-the-uk-internal)
- [9. Preparation, approval and publication record (internal)](#9-preparation-approval-and-publication-record-internal)
- [10. Glossary and references](#10-glossary-and-references)
- [Standard and licence note](#standard-and-licence-note)

## 1. Applicability and statutory basis (internal)

<!-- Guidance: Purpose: prove that the business must publish and under which paragraph. Questions: Did the UK group, sub-group or company exceed GBP 200m turnover or GBP 2bn balance sheet total in the previous financial year? Is it part of a multinational group above the EUR 750m country-by-country reporting threshold? Does a strategy published higher in the group already cover it? Pitfall: applying the UK size test to a business in a multinational group; the two tests are separate. -->

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.

| Test ID | Test | Data for previous financial year | Result |
|---|---|---|---|
| APP-001 *(Example)* | UK turnover above GBP 200m | Ostrander UK Ltd FY2025: GBP 118m (EUR 137m) | Not met |
| APP-002 *(Example)* | UK balance sheet total above GBP 2bn | GBP 61m | Not met |
| APP-003 *(Example)* | Multinational group above EUR 750m (country-by-country reporting) | Ostrander Group N.V. consolidated revenue FY2025: EUR 820m | Met |
| APP-004 *(Example)* | Strategy published higher in the group that covers the UK | No group strategy published in the Netherlands | Not covered |
| Result | | | Must publish for FY2026 |

### 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.

| Publisher type | Paragraph to cite (check) |
|---|---|
| Head of a UK group | Paragraph 16(2) |
| UK sub-group (UK entities of a foreign-headed group) | Paragraph 19(2) |
| Qualifying UK company not in a group | Paragraph 22(2) |
| Qualifying partnership | Paragraph 25(1) |

*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)

<!-- Guidance: Purpose: tell the reader who the strategy covers, for which year, and under which law it is published. Questions: Which entities are covered? Is the statutory statement present? Pitfall: omitting the paragraph reference or the financial year, which makes the strategy non-compliant. -->

[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)

<!-- Guidance: Purpose: describe how UK tax risks are identified, managed and overseen, including board oversight. Questions: Who is accountable for tax at board level? Who manages tax day to day? Which processes and controls exist? How are risks escalated? Pitfall: describing a policy without saying who applies it or how the board knows it works. -->

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.

| Governance element | Owner | Frequency | Evidence held (internal) |
|---|---|---|---|
| Strategy approval | Board of the publishing entity | Annual | Board minutes |
| Tax risk reporting | Group head of tax to audit committee | Twice a year | Committee papers |
| Tax control review | Group head of tax and internal audit | Annual | Control testing results |
| Prevention of facilitation of tax evasion | Group head of tax and compliance | Annual risk assessment | Risk assessment and training records |

## 4. Attitude towards tax planning (published)

<!-- Guidance: Purpose: state how the business approaches tax planning and the use of reliefs and incentives. Questions: Does the business use tax planning only where it supports genuine commercial activity? Does it take external advice? How does it treat government incentives? Does it use low-tax jurisdictions, and why? Pitfall: vague statements such as "we pay our fair share" with no explanation of what the business does and does not do. -->

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)

<!-- Guidance: Purpose: state the level of tax risk the business is prepared to accept. Questions: Is the appetite low, moderate or higher, and what does that mean in practice? Which decisions require escalation? Pitfall: claiming "zero risk", which is not credible because tax law is complex and some judgement is unavoidable. -->

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.

| Risk level (internal mapping) | Example of a position | Approval |
|---|---|---|
| Low *(Example)* | Applying a well-established relief to a qualifying activity | Head of tax |
| Moderate *(Example)* | Interpreting new legislation where guidance is limited, with advice | Group CFO |
| Outside appetite *(Example)* | A position the business expects to lose if challenged | Not permitted |

## 6. Working with HMRC (published)

<!-- Guidance: Purpose: describe how the business deals with HMRC. Questions: Does the business work openly with HMRC? How does it handle disclosures, errors and disputes? Does it engage in real time on uncertain matters? Pitfall: a statement that contradicts the business's actual record with HMRC. -->

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)

<!-- Guidance: Purpose: add voluntary information that builds trust. Questions: Does the business want to show its total tax contribution, its approach to Pillar Two, its country-by-country information or links to sustainability reporting? Pitfall: publishing numbers that do not reconcile to the financial statements or to the country-by-country report. -->

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.

| Optional topic | Include? | Source to reconcile |
|---|---|---|
| Taxes paid and collected in the UK *(Example)* | No for FY2026; review for FY2027 | Ledger and tax returns |
| Pillar Two position *(Example)* | Yes, in section 4 | Pillar Two assessment |
| Link to the group sustainability report *(Example)* | Not applicable | Group sustainability report |
| Public country-by-country information *(Example)* | Not applicable for the UK entity; group reviews EU public CbCR scope separately | CbC workpaper |

## 8. Using the template outside the UK (internal)

<!-- Guidance: Purpose: reuse the same structure for voluntary or local tax transparency statements. Questions: Does another country require or encourage a published tax strategy or tax transparency report? Does the business report under a sustainability standard that includes tax? Pitfall: publishing one global statement that misses a local requirement, such as a specific paragraph reference. -->

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.

| Jurisdiction or framework | Status as of 2026-10 (check local law) | How to adapt |
|---|---|---|
| United Kingdom: Finance Act 2016, Schedule 19 | Mandatory for qualifying businesses | Use this template as written |
| Australia: Voluntary Tax Transparency Code (Board of Taxation) | Voluntary, name only | Add the code's reporting items as a separate section |
| European Union: public country-by-country reporting (Directive (EU) 2021/2101) | Mandatory for in-scope groups from financial years starting on or after 2024-06-22 | Link the public report from section 7 |
| Global Reporting Initiative: GRI 207 Tax (2019) | Voluntary sustainability disclosure, name only | Map sections 3 to 6 to the standard's topics |
| Other jurisdictions | Check for local transparency or cooperative compliance programmes | Replace "HMRC" with the local authority |

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)

<!-- Guidance: Purpose: evidence that the strategy was prepared, approved and published on time and kept available. Questions: Who drafted and reviewed it? When did the board approve it? Where is it published and how is the page archived? Pitfall: a website change that removes the strategy before the next one is published. -->

| Step ID | Step | Owner | Due | Done | Evidence |
|---|---|---|---|---|---|
| PUB-001 *(Example)* | Confirm applicability tests (section 1) | [@head-of-tax] | 2026-09-30 | YYYY-MM-DD | Test table |
| PUB-002 *(Example)* | Update draft for law changes and business changes | [@head-of-tax] | 2026-10-15 | YYYY-MM-DD | Marked-up draft |
| PUB-003 *(Example)* | Legal and communications review | [@legal], [@communications] | 2026-10-31 | YYYY-MM-DD | Review notes |
| PUB-004 *(Example)* | Board approval | [@board-chair] | 2026-11-20 | YYYY-MM-DD | Minutes |
| PUB-005 *(Example)* | Publish on website, free of charge and easy to find | [@web-owner] | 2026-11-30 | YYYY-MM-DD | URL and screenshot |
| PUB-006 *(Example)* | Archive copy and check link quarterly | [@head-of-tax] | Quarterly | YYYY-MM-DD | Archive file and check log |

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

<!-- Guidance: Keep definitions plain for an external reader. List the version of every source used, because HMRC guidance is updated from time to time. -->

### 10.1 Glossary

| Term | Meaning in this template |
|---|---|
| Arm's length principle | Pricing between related companies as if they were independent parties |
| Country-by-country report | Annual report by large multinational groups showing key data for each country |
| HMRC | His Majesty's Revenue and Customs, the UK tax authority |
| Pillar Two | The global minimum tax rules that aim for an effective tax rate of at least 15% per country |
| Qualifying conditions | The size or multinational tests that make publication mandatory |
| Tax risk appetite | The level of uncertainty in tax positions the business is willing to accept |
| UK sub-group | The UK entities of a group headed outside the UK |

### 10.2 References

| Reference | Version or date checked | Use |
|---|---|---|
| Finance Act 2016, Schedule 19 (legislation.gov.uk) | As amended, checked 2026-10-25 | Statutory basis and paragraph references |
| HMRC, "Large businesses: publish your tax strategy" (gov.uk, OGL v3.0) | Last updated 2024-07-30 | Qualifying tests, content, timing, publication and penalties |
| Finance Act 2009, Schedule 46 | Name only | Senior accounting officer cross-reference |
| Criminal Finances Act 2017, Part 3 | Name only | Failure to prevent facilitation of tax evasion |
| HMRC Charter | Name only | Section 6 |
| OECD Transfer Pricing Guidelines (2022 edition) | Name only | Section 4 |
| Directive (EU) 2021/2101 (public country-by-country reporting) | Name and application date | Section 8 |
| Australian Voluntary Tax Transparency Code; GRI 207 Tax (2019) | Names only | Section 8 |

## 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.