HMRC published guidance on 24 June 2016 on the proposed requirement for large businesses to publish an annual tax strategy.
The guidance summarises briefly the criteria that must be met for the requirement to apply, the required content of a tax strategy, how and when a strategy must be published and the penalties for non-compliance, all of which reflect the Finance Bill 2016 legislation and the draft guidance published on 31 March 2016. However, the guidance, which is published in a different part of the gov.uk website to the draft guidance, is significantly shorter and omits detailed information on the scope of the rules, specific guidance for multinational groups and the detailed commentary on penalties and the defence of reasonable excuse that were included in the draft guidance. It is unclear whether the guidance replaces the draft guidance (or is an additional document intended for different users) and, therefore, whether the omitted commentary can be relied upon.
Please note that the above does not constitute legal advice.