How to share group structure information with HMRC: what GfC17 means for large businesses

What is HMRC’s guidance for compliance 17 (GfC17)

HM Revenue & Customs (HMRC) has published new guidance titled Help with sharing group structure information – GfC17. It’s aimed at large and complex businesses and sets out how those businesses can share clear information about their group structure and related transactions with HMRC.

The guidelines are not mandatory, but HMRC encourages their use to reduce misunderstandings and support more efficient interactions. It also encourages a more collaborative approach during reviews, enquiries and routine engagement.

Why HMRC introduced GfC17 guidance for large businesses

HMRC wants to help multinational businesses and groups with complex arrangements to present group information in a way that is clear, complete and easy to interpret. The aim is to avoid unnecessary clarification, reduce delays and give HMRC the context it needs to understand a group’s structure and transactions.

The guidance is designed to be used alongside HMRC’s existing manuals. This information helps HMRC understand how a group’s structure and activities affect its position for corporation tax, VAT and customs duty.

When large businesses need to share group structure information with HMRC

HMRC requests group structure information to support a range of interactions, including:

• Statutory clearance applications
• Advanced Pricing Agreement requests
• Profit Diversion Compliance Facility disclosures
• Information requests during compliance checks
• Updates shared as part of the Business Risk Review+ (BRR+) process

In all of these situations, the clarity of the information provided can help HMRC understand the position more quickly.

What HMRC considers ‘good’ group structure information

HMRC sets out key information that should be included in any structure chart or supporting explanation. This covers:

• The entity type and full legal name
• Ownership and control, including how control is exercised
• The country of incorporation and if different the country of tax residence
• Any special characteristics, such as whether an entity is a hybrid, charity, joint venture or a limited, limited liability or Scottish partnership

HMRC notes that businesses can continue to use existing records, but should check that this information is included and clearly explained. If there are differences between current documentation and the approach suggested in the guidance, these should be highlighted and explained.

How to present complex group structures clearly

To promote consistency, HMRC provides standard shapes and symbols to illustrate different entities and relationships. Using these symbols is optional. However, adopting them helps ensure the information is easy for HMRC staff to review and reduces the chance of misinterpretation.

For more complex groups, HMRC includes a table format which can be used to capture information for each entity. This can be used alongside existing tables, such as those created for country-by-country reporting (CbCR) and helps ensure all relevant details are brought together in one place.

Why GfC17 matters for governance, tax integrity and risk management

While optional, GfC17 aligns closely with HMRC’s expectations for transparent and well‑governed tax functions. Clear group structure information supports:

• Faster and more efficient interaction
• Fewer follow‑up questions
• A stronger foundation for low‑risk ratings under BRR+
• Internal clarity over ownership, control and tax attributes across the group

For many groups, reviewing structure information is a simple step that can support wider tax risk management and improve the quality of engagement with HMRC.

Practical steps large businesses should take now

Consider reviewing your existing group structure materials, such as:

1. Checking that all ownership, control and jurisdiction details are up to date and clearly shown.
2. Reviewing whether any entities with special characteristics are presented in line with HMRC’s expectations.
3. Ensuring diagrams are supported with explanations where the structure is unusual.
4. Using HMRC’s standard symbols where they help improve clarity.
5. Using tables to present more complex structures.

Where to find official HMRC resources

Help with sharing group structure information – GOV.UK

Appendix A — standard shapes and symbols – GOV.UK

Appendix B — practical examples – GOV.UK

How Saffery supports large businesses with HMRC interactions

Our team of corporate tax experts help large businesses with all aspects of tax risk and governance, including reviewing their group structure information and ensuring they align with HMRC’s expectations. Whether you want input into your group structure information or with your interactions with HMRC, we can help you.