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Extending the definition of a Significant Global Entity (SGE)

Key documents

The Government announced in the 2018-19 Budget that it was extending the definition of a Significant Global Entity (SGE) to include members of large business groups headed by proprietary companies, trusts, partnerships and investment entities.

A Significant Global Entity (SGE) is a concept to define, generally speaking, a group of entities, interrelated by a control relationship that could enable non-arm’s length dealings and therefore be of special interest to tax authorities.

Originally devised to determine application of OECD Country by Country reporting requirements, the SGE definition is now also used to determine application of the Multilateral Anti-Avoidance Law, the Diverted Profits Tax and penalties applying to false or misleading statements, late lodgement or tax schemes. Also SGEs are required to prepare general purpose financial statements where a non-SGE would only be required to prepare special purpose financial statements.

The current SGE definition however only includes groups headed by listed companies and private companies required to prepare general purpose financial statements. By extending the definition, the proposed legislation will ensure the multinational tax avoidance rules apply to all relevant entities.


You can submit responses to this consultation up until 17 August 2018.

Interested parties are invited to comment on this consultation.

While submissions may be lodged electronically or by post, electronic lodgement is preferred. For accessibility reasons, please submit responses sent via email in a Word or RTF format. An additional PDF version may also be submitted.

All information (including name and address details) contained in submissions will be made available to the public on the Treasury website unless you indicate that you would like all or part of your submission to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Respondents who would like part of their submission to remain in confidence should provide this information marked as such in a separate attachment.

Legal requirements, such as those imposed by the Freedom of Information Act 1982, may affect the confidentiality of your submission.

How to respond


Address written submissions to:

Base Erosion and Profit Shifting Unit
Corporate and International Tax Division
The Treasury
Langton Crescent