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HMRC internal manual

Special Measures

SM02000 - Special Measures: Entities in Scope

Special Measures legislation applies to large UK groups, UK sub-groups of a foreign group, UK companies and UK partnerships who demonstrate persistently unco-operative behaviour (SM03000) in their relationship with HMRC.

For the purposes of this guidance, a “large business” is considered in scope where either or both of the following thresholds are met in the previous financial year:

  • the turnover must be more than £200 million
  • the balance sheet total must be more than £2 billion

These thresholds are used to identify entities of a scale and complexity that align with the intended application of Special Measures.

Throughout this guidance, the term “large business” refers to entities or groups meeting one or both of these criteria.

A company is a member of a group for the purposes of Special Measures legislation if another company is its 51% subsidiary, or it is a 51% subsidiary of another company. Two companies are members of the same group if one is a 51% subsidiary of the other or both are 51% subsidiaries of another company.

This meaning of a 51% subsidiary uses the Chapter 3, Part 24 of CTA 2010 interpretation as it applies for the purposes of the Corporation Tax Acts.