BNA Snapshot
• Lawmakers put public global tax reports into U.K. law in 2016
• Some U.K. companies will file first private reports this month
The U.K. will reconsider the case for making multinational companies’ global tax reports public, a decision that would make the country the first to take the step.
In its Dec. 14 departmental report for 2018, the U.K.’s tax authority said it will review international rules for the global tax reports and “consider the case” for making them publicly available.
Known as country-by-country reporting, the filings are the most widely adopted policy from the OECD's project to curb tax avoidance among multinationals. The measure provides a clear picture of companies’ finances, such as profits and taxes paid, for each country in which they operate.
While the reports are currently private, the U.K. became in September 2016 the first country to include country-by-country reporting in its legislation. Lawmakers included the measure as an amendment to the Finance Bill 2016, giving the U.K. Treasury power to adopt it officially. The European Union, meanwhile, is still considering its April 2016 proposal for the same measure.
Deadline Approaching
The disclosure from Her Majesty's Revenue and Customs comes as U.K. multinationals are in the process of filing their first country-by-country reports to the tax authority. The measure only applies to companies with annual group revenue of at least 750 million euros ($883.5 million).
Under the Organization for Economic Cooperation and Development's guidance, companies should file their reports within 12 months of the relevant fiscal year. In line with the U.K.’s Finance Act 2015, any company with a calendar year-end for its accounts must file by Dec. 31, 2017.
More than half of companies listed on the U.K.’s FTSE 100 stock market index have calendar year-ends, according to data compiled by Bloomberg Tax. In total, around 300 U.K. multinationals will have to file country-by-country reports to HMRC, according to an official policy paper.
Making the reports publicly available wouldn't come as too much of a shock for companies, some of which are already anticipating that countries outside the U.K. will leak the information.
“We are working on the basis that it will become public one way or another,” Vodafone Group Plc's group tax director, John Connors, said last month.
Rich Targeted in 2018
In addition to reconsidering public country-by-country reporting, HMRC said in its departmental plan it will target more wealthy individuals next year in its efforts to boost taxpayer compliance.
HMRC will “extend our model for the wealthiest individuals to a further 2,000 individuals.” These individuals have a net worth between 10 million and 20 million pounds, it added.
The U.K. has around 6,500 high-net-worth individuals, according to a November 2016 National Audit Office report. While they represent fewer than 0.05 percent of U.K.’s taxpayers, these individuals paid 4.3 billion pounds to HMRC in the financial year that ended in March 2015, the report added.
Tax Planning Exposed
HMRC's departmental plan comes after last month's Paradise Papers data leak, which exposed the offshore tax planning of wealthy individuals and multinational companies, including Apple Inc.
The data included 6.8 million files from Bermuda-based law firm Appleby. Nearly 14,500 of Appleby's clients in the leak are linked to the U.K., the second-highest number of country connections after the U.S.
Published Nov. 5, the leak also revealed that British-born businessman Michael Ashcroft had a hidden Bermuda trust with assets of $450 million, the Guardian newspaper reported.
HMRC said Dec. 14 it aims to collect 28 billion in tax via its compliance and enforcement activity. Last year, the authority collected 574.9 billion pounds in total taxes. HMRC's latest compliance target, meanwhile, is 900 million pounds below its yield for the previous financial year.
To contact the reporter on this story: Benjamin Stupples in London at bstupples@bna.com
To contact the editor responsible for this story: Penny Sukhraj at psukhraj@bloombergtax.com