BKM503500 | The Code commitments – governance: comply fully with all tax obligations

A Code adopter is expected to have governance in place to make sure it meets all its tax obligations, which include, but are not limited to, taking reasonable care to ensure all tax returns are complete, correct and filed on time.

Where a bank makes an error in a return, HMRC will potentially look at the bank’s governance to see if it has any concerns. HMRC will take into account the behaviour that led to the error. Errors can arise despite reasonable care, and such isolated failures will not generally lead to escalation under the Governance Protocol. HMRC will not generally escalate isolated incidents of late returns or payments.

Deliberately incorrect returns or multiple failures indicating a lack of effective governance controls are likely to raise concerns that would be escalated in accordance with the Governance Protocol.