BKM509200 - Interaction of the Code with other measures: Code and special measures
»Ê¹ÚÌåÓýapp Government introduced special measures in FA16/SCH19/PART3 “to impact a small section of Large Businesses who persistently engage in aggressive tax planning and/or who refuse to engage with HM Revenue and Customs (HMRC) in an open and collaborative way.â€�
Compliance with the Code requires a bank to maintain an open and collaborative relationship with HMRC and to refrain from engaging in aggressive tax planning. It is therefore unlikely that a Code compliant bank would be subject to special measures.
However, a bank does not have to be found to be in breach of its obligations under the Code in order to be subjected to special measures. »Ê¹ÚÌåÓýapp two regimes are independent of each other.