SCHEDULES
SCHEDULE 19Large businesses: tax strategies and sanctions
PART 2Publication of tax strategies
Penalty for non-compliance with requirements of paragraph 19
21
1
This paragraph applies where paragraph 19 requires a sub-group tax strategy to be published for a UK sub-group in any financial year of the head of the sub-group.
2
The head of the sub-group is liable to a penalty of £7,500 if—
a
there is a failure to publish a sub-group tax strategy for the sub-group that complies with paragraph 19(2), or
b
where a sub-group tax strategy has been published, there is a failure to comply with paragraph 19(5).
3
Subject to sub-paragraph (5), the head of the sub-group is only liable to one penalty by virtue of sub-paragraph (2) in respect of a sub-group tax strategy required for the financial year in question.
4
Sub-paragraph (5) applies where—
a
the head of the sub-group is liable to a penalty under this paragraph in respect of a failure mentioned in sub-paragraph (2)(a), and
b
no sub-group tax strategy for the sub-group that complies with paragraph 19(2) (disregarding paragraph 19(3)) is published within the period of 6 months after the last day on which the duty under paragraph 19(2) could have been complied with.
5
At the end of that period, the head of the sub-group is liable—
a
to a further penalty of £7,500, and
b
where the failure mentioned in sub-paragraph (4)(b) continues, to a further penalty of £7,500 at the end of each subsequent month in which no such sub-group tax strategy is published.