FA 2016, Sch 19 Part 3 provides for sanctions persistently uncooperative large businesses.
A business which persistently engages in uncooperative behaviour which gives rise to a significant tax issue may result in HMRC issuing the business with a warning notice. Subsequent uncooperative behaviour may result in the issuing of a special measures notice, the effect of which is that:
- Ìý
•ÌýÌýÌýÌý an inaccuracy in a document may, for the purposes of FA 2007, Sch 24 (penalties for errors) be regarded as resulting from a failure to take reasonable care
- Ìý
•ÌýÌýÌýÌý information relating to the business may be published
A more detailed description of the provisions is set out below.
Application
The legislation applies to:
- Ìý
•ÌýÌýÌýÌý a UK group, ie two or more companies or other bodies corporate (other than limited liability partnerships) whose head is incorporated in the UK1
- Ìý
•ÌýÌýÌýÌý a UK company, ie a company formed and registered under CA 2006 other than an open-ended investment company within the meaning of
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