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HMRC ‘tax under consideration’ from large businesses

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HMRC has followed up its annual report and accounts with a breakdown of ‘tax under consideration’ from tax disputes with large businesses, amounting to £29.9bn at 31 March 2019.

Tax under consideration is an estimate of the maximum potential additional tax liability in specific cases before HMRC has carried out a full investigation. HMRC uses these figures to focus its enquiries on the most significant risks at any given time among the largest businesses.

The figure of £29.9bn breaks down by parent company location into UK (£20bn), non-UK (£9.7bn) and mixed UK/non-UK (£0.2bn). The average length of time taken to settle enquiries during 2018/19 was 15 months. See

Research carried out by Thomson Reuters indicates that UK FTSE 100 groups made provisions amounting to £4.5bn to cover tax disputes in 2018/19. This is a drop from £5.2bn set aside in 2017/18, which commentators believe reflects the fact that the first major group of investigations begun following introduction of the diverted profits tax in 2015 have now largely run through the system. However, Thomson Reuters sees a growing appetite among tax authorities in developing countries for launching investigations into multinational groups, as pressure grows in those countries to raise revenues for public services and infrastructure spending.

Issue: 1454
Categories: News