BKM503300 | The Code commitments – governance: for a small bank

The governance requirements for a small bank are not set out in detail in the Code. This is to provide these institutions with a more flexible and appropriate approach to documenting and governing their strategy towards tax which is proportionate to, and consistent with, HMRC’s risk strategy. However, the principles underpinning that strategy should be the same as those for larger banks that adopt the Code in its entirety.

Many of these small banks are part of a group with a global turnover of more than €750 million and are required to publish their tax strategy for financial years beginning after 15 September 2016. See BKM509000 for further details on the interaction between the Code and the requirement for large businesses to publish their tax strategy.