Upcoming UK corporation tax deadlines – CBCR, tax strategy publication, SAO, QIPs
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Upcoming UK corporation tax deadlines – CBCR, tax strategy publication, SAO, QIPs
Upcoming UK corporation tax deadlines – CBCR, tax strategy publication, SAO, QIPs
Mon 23 Dec 2019
Many companies have 31 December year ends and in addition to corporation tax return filing deadlines, it may be helpful to consider other upcoming UK tax reporting deadlines. Some of these are noted below. There may well be other deadlines to consider for tax purposes. For further advice on corporation tax matters, please get in touch with a member of the Mazars corporate tax team.
Country by country reporting:
This is relevant for an ‘MNE group’ that meet an annual global €750m consolidated turnover threshold in the immediately preceding year (for example the threshold must be met in YE 31 December 2018 for application of the rules to YE 31 December 2019) .
- Filing of CBCR reports by 31 December 2019 for the YE 31 December 2018.
- Notifications of the reporting entity by ‘UK constituent entities’ by 31 December 2019 for the YE 31 December 2019. Remember a UK permanent establishment can be a UK constituent entity.
Publication of a tax strategy:
This is relevant for groups/companies/partnerships meeting a size threshold for the previous financial year. This can be either (i) the CBCR size threshold, or (ii) for UK groups that meet a £200m aggregate gross asset or £2bn aggregate gross turnover threshold.
Where the size threshold is breached (for example for the YE 31 December 2018) the tax strategy report must be published before the end of the current financial year (for example 31 December 2019). It must be renewed each year and cannot be published later than 15 months after the last one.
There are penalties for non-compliance starting at £7,500.
Senior Accounting Officer rules:
This applies to UK incorporated companies which breach a £200m aggregate gross asset or £2bn aggregate gross turnover threshold for the company/group for the previous financial year.
- Companies within scope must notify HMRC of the individual who is the SAO by the financial statement filing deadline (normally 6m after the year end for a public company and 9m after the year end for other companies). This notification must be made each year.
- A certificate stating whether the company has appropriate accounting records or not for tax purposes must be filed by the financial statement filing deadline (normally 6m after the year end for a public company and 9m after the year end for other companies) for each year.
There are penalties for both the nominated individual SAO and the company for non-compliance. If no individual SAO is nominated, it appears the only penalty is the £5,000 company penalty.
Quarterly instalment payments (QIPS)
When considering advising on QIPS, please pay particular attention to whether this is within the scope of our engagement letter.
Quarterly instalment payments apply for companies which are deemed ‘large’. Large is assessed according to whether its profits chargeable to corporation tax (including those that might be subject to NRCGT) for the current period exceed an annual £1.5m threshold and all those subject to the bank levy. There is a 12m grace period for companies whose profit threshold is below £10m and who did not exceed the £1.5m threshold in the previous year (or were dormant or did not exist). This is subject to a £10,000 deminimis limit.
The profit threshold is reduced depending on the number of associated companies existing at the previous accounting period (or start of the current period if no previous period existed), excluding dormant companies. Associated companies includes companies within a 51% group, wherever they are resident, but does not include dormants. This is set out in SI 1999/3175 and CTA 2010 s279F (and also HMRC guidance at CTM92520 and CTM03570).
Quarterly instalments for a company that is not ‘very large’ are different to those that are ‘very large (where the threshold used is £20m instead of £1.5m) and are set out below. The payment dates for ‘very large’ companies all fall within the accounting period. This ‘very large’ category applies for accounting periods commencing on or after 1 April 2019. Therefore for companies with a 31 December year end, the first accounting period to which the ‘very large QIPs payment dates could apply is the year ended 31 December 2020.
QIPS for large, but not very large companies:
- First instalment – 6 months & 13 days from the start of the accounting period
- Second instalment – 9 months & 13 days from the start of the accounting period
- Third instalment – 12 months & 13 days from the start of the accounting period
- Fourth instalment – 15 months & 14 days from the start of the accounting period
- Any final instalment – 9 months after the end of the accounting period
QIPS for very large companies:
- First instalment – 2 months & 13 days after the start of the accounting period
- Second instalment – 5 months & 13 days after the start of the accounting period
- Third instalment – 8 months & 13 days after the start of the accounting period
- Fourth instalment – 11 months & 13 days after the start of the accounting period
- Any final instalment – 9 months after the end of the accounting period
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