17(1)A group tax strategy required to be published on behalf of a UK group by paragraph 16 must set out—U.K.
(a)the approach of the group to risk management and governance arrangements in relation to UK taxation,
(b)the attitude of the group towards tax planning (so far as affecting UK taxation),
(c)the level of risk in relation to UK taxation that the group is prepared to accept, and
(d)the approach of the group towards its dealings with HMRC.
(2)The group tax strategy may—
(a)include other information relating to taxation (whether UK taxation or otherwise), and
(b)deal with a matter mentioned in sub-paragraph (1) by reference to the group as a whole or to individual members of the group (or to both).
(3)The information required by sub-paragraph (1) to be included in the group tax strategy does not include any information about activities of any member of the group that consists of the provision of tax advice or related professional services to persons who are not members of the group.
(4)The publication of information as the group tax strategy does not constitute publication of the strategy for the purposes of paragraph 16 unless the UK company publishing it makes clear (in a way that will be readily apparent to anyone accessing the information online) that the company regards its publication as complying with the duty under paragraph 16(2) in the current financial year.
(5)For the purposes of this paragraph a UK permanent establishment of a foreign member of the group is to be treated as if it were a member of the group.
(6)The Treasury may by regulations require the group tax strategy to include a country-by-country report.
(7)In this paragraph “country-by-country report” has the meaning given by the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016.