Every year, growing groups reach year-end with the same avoidable problem: the tax provision. It arrives late, the deferred tax doesn't reconcile, the auditors raise queries no one can answer quickly, and a process that should take days stretches into weeks — holding up the accounts, the board pack, and sometimes the audit sign-off itself. This guide explains what the tax provision actually is, why it goes wrong so predictably, and how a business gets it right — with a worked example running through it: a real tax note, the journals behind it, the effective tax rate reconciliation auditors expect, and the exchanges where the tax team defends its judgements. It is written from the perspective of someone who has built these provisions in-house and sat opposite the auditors.
What the tax provision actually is
The tax provision is the tax figure that goes into your financial statements — the current tax you owe on this year's profit, plus the deferred tax that reflects timing differences between when the accounts recognise something and when tax does. It is not the same as the tax return. The return is filed with HMRC months later; the provision is the number the accounts show now, at year-end, and it is the number the auditors examine and the board relies on.
That distinction is where most of the trouble starts. A business with a competent accountant to file the return can still make a mess of the provision, because the provision is an accounting exercise governed by FRS 102 (or IAS 12 for larger groups), not a compliance exercise. It requires reconciling the tax charge back to the accounting profit, identifying every timing difference, recognising or not recognising deferred tax on losses, and presenting the whole thing in a way an auditor can follow. Getting the return right and getting the provision right are two different skills — and the second is the one mid-market businesses most often lack.
📌 The worked example we'll follow
The business: A UK trading company, part of a growing group, with a 31 December 2026 year end. Profit before tax of £2,400,000. It has £600,000 of capital additions qualifying for accelerated capital allowances, a £180,000 provision for a legal dispute (not yet tax-deductible), £90,000 of share-based payment expense, £40,000 of disallowable entertaining, and £250,000 of carried-forward trading losses from a weaker prior year.
The task: arrive at the current and deferred tax figures, the journals, and a disclosure note that survives audit — while making, and being able to defend, the judgement on whether to recognise a deferred tax asset on those losses.
Building the current tax charge
Current tax starts from accounting profit and adjusts for the things tax treats differently. Working through the example, disallowables are added back, capital allowances replace accounting depreciation, and the non-deductible provision and share-based payment are added back because tax relief comes later (or on a different trigger):
| Item | £ |
|---|---|
| Profit before tax | 2,400,000 |
| Add: disallowable entertaining | 40,000 |
| Add: legal provision (not yet allowable) | 180,000 |
| Add: share-based payment (relief on exercise) | 90,000 |
| Add: depreciation (replaced by allowances) | 220,000 |
| Less: capital allowances | (600,000) |
| Taxable profit before losses | 2,330,000 |
| Less: carried-forward losses utilised | (250,000) |
| Taxable profit | 2,080,000 |
| Current tax at 25% | 520,000 |
The losses have been fully used this year, which matters for the deferred tax question below — there is now no loss asset left to recognise, only the timing differences.
The deferred tax trap
If the provision has a single failure point, it is deferred tax. It is conceptually harder than current tax, it is where auditors focus their scrutiny, and it is where the errors that damage credibility live. Deferred tax captures the future tax effect of timing differences — amounts the accounts have recognised but tax hasn't yet, or vice versa. In the example, three timing differences drive it:
| Timing difference | Amount £ | Deferred tax at 25% £ |
|---|---|---|
| Accelerated capital allowances (allowances > depreciation) | 380,000 | 95,000 liability |
| Legal provision (relief on payment) | 180,000 | 45,000 asset |
| Share-based payment (relief on exercise) | 90,000 | 22,500 asset |
| Net deferred tax liability | 27,500 |
The recurring errors cluster here, and they are worth naming precisely (each is worked through in detail in our guide to common deferred tax errors and how auditors catch them):
- Recognising a deferred tax asset on losses that shouldn't be recognised. A deferred tax asset on carried-forward losses can only be recognised to the extent future profits are probable. Groups routinely recognise the full asset on optimism, and the auditor writes it down. In our example the losses were used this year, so the question doesn't arise — but had they not been, the recognition judgement would be the single most scrutinised line in the file (see the auditor exchange below).
- Missing timing differences entirely. Miss the share-based payment or the provision and the deferred tax is wrong, and the error often persists year on year until someone unpicks it.
- Applying the wrong rate. Deferred tax is measured at the rate expected when the difference reverses — 25% here. A blended or outdated rate misstates the balance.
- Not reconciling the movement. The movement in the deferred tax balance must reconcile to the deferred tax charge in the income statement. When it doesn't, and no one can say why, the auditor's confidence in the whole provision drops.
The journals
With current and deferred tax established, the postings follow. Presenting the journals cleanly — with a one-line rationale against each — is part of what makes a file audit-ready rather than a black box:
Journal 1 — Current tax charge
Dr Tax charge (P&L) £520,000
Cr Corporation tax payable (balance sheet) £520,000
Being current tax on taxable profit of £2,080,000 at 25%.
Journal 2 — Deferred tax movement
Dr Tax charge (P&L) £27,500
Cr Deferred tax liability (balance sheet) £27,500
Being the movement in net deferred tax, driven mainly by accelerated capital allowances net of the provision and share-based payment timing differences, at 25%.
Total tax charge to P&L: £547,500 (£520,000 current + £27,500 deferred).
Where a timing difference relates to an item taken to equity or other comprehensive income rather than the P&L — a share-based payment excess, say, or a revaluation — the deferred tax on it follows the same route and is posted to equity/OCI, not the P&L. Getting that split right is a common auditor check, and a common place mid-market provisions slip.
The effective tax rate reconciliation auditors expect
A provision that audits smoothly always includes the reconciliation from accounting profit at the standard rate down to the actual tax charge, with every reconciling item explained. This is the first thing an experienced auditor turns to, because it exposes whether the numbers hang together. For the example:
| Effective tax rate reconciliation | £ |
|---|---|
| Profit before tax | 2,400,000 |
| Tax at standard rate 25% | 600,000 |
| Tax effect of disallowable entertaining (£40,000 × 25%) | 10,000 |
| Deferred tax not previously recognised on losses now utilised | (62,500) |
| Total tax charge | 547,500 |
| Effective tax rate | 22.8% |
The reconciliation tells the story the board needs in one view: the effective rate is below 25% principally because losses that carried no deferred tax asset last year were used this year, permanently benefiting the charge. That is a defensible, explainable position — and the reconciliation is what lets you defend it in a sentence rather than a scramble.
The disclosure note
The tax note in the accounts is where all of this becomes public — to the board, and to any investor or lender who reads the statements. A clear note signals control; a vague or non-reconciling one invites questions. Here is how the example's note reads:
Note X — Taxation
Analysis of tax charge for the year
Current tax — UK corporation tax: £520,000
Deferred tax — origination and reversal of timing differences: £27,500
Total tax charge: £547,500
Reconciliation of tax charge
Profit before tax £2,400,000; tax at 25% £600,000; effect of expenses not deductible £10,000; effect of losses previously unrecognised now utilised (£62,500); total tax charge £547,500.
Deferred tax balance
Accelerated capital allowances £95,000 (liability); short-term timing differences £67,500 (asset); net deferred tax liability £27,500. Measured at 25%, the rate expected to apply on reversal.
How auditors assess it — and how the tax team responds
Auditors are not permitted to prepare your provision; their role is to examine what you present and challenge the judgements. A provision prepared for the auditor — assuming it will be scrutinised, because it will be — turns the audit from a scramble into a routine. The difference shows in how queries are handled. Three exchanges illustrate what "defending the judgement" actually looks like:
Auditor query 1 — deferred tax on losses. "Last year the group carried £250,000 of losses with no deferred tax asset recognised. What was the basis for non-recognition, and why are they now benefiting the charge?"
Tax team response. "At the prior year end, future profits were not sufficiently probable to support recognition under FRS 102 — the trade had just returned to break-even and the forecast was not yet reliable. We therefore did not recognise the asset, which was the prudent position. This year the company returned to sustained profitability and the losses have been fully utilised against taxable profit, so the benefit crystallises in the current-year charge rather than as a balance sheet asset. The reconciliation shows this as a £62,500 reconciling item." The judgement is consistent across both years and documented — which is exactly what the auditor is testing for.
Auditor query 2 — completeness of timing differences. "How have you satisfied yourselves that all timing differences are captured, particularly the share-based payment?"
Tax team response. "We reconcile the deferred tax schedule to the fixed asset register (for capital allowances), the provisions listing, and the share scheme records. The £90,000 share-based payment charge gives a £22,500 deferred tax asset, recognised because relief is expected on exercise and the company is profit-making. Here is the schedule tying each difference to its source ledger." Tying every difference to a source document is what turns "trust me" into audit evidence.
Auditor query 3 — the rate. "Confirm the rate applied to deferred tax and why."
Tax team response. "25% throughout — the main rate enacted and expected to apply when these differences reverse. No differences are expected to reverse in a period attracting a different rate, so no blending is required." Short, precise, closed. The query ends there.
The pattern is the same in each: the judgement was made deliberately, documented at the time, tied to evidence, and can be explained in a sentence. That is the difference between a provision that clears audit in an afternoon and one that drags on for weeks. It is also, bluntly, what an experienced in-house tax function does as routine and a general-practice preparer often cannot.
What it costs you to get it wrong
The reason the provision deserves this much attention is that the cost of getting it wrong is rarely just a corrected number. It compounds — into restatement, lost trust, and a heavier burden every year after. The consequences that actually bite:
- Restatement. If a material provision error is found after the accounts are signed, the business may have to restate prior-year figures. A restatement is public, it is remembered, and it is one of the clearest signals to an outside reader that financial control is weak. Nothing undermines confidence in a finance function faster.
- A qualified or delayed audit opinion. If the auditor cannot get comfortable with the provision, the audit stalls — or worse, the opinion is modified. A delayed sign-off ripples into filing deadlines, covenant reporting and investor updates; a modified opinion is a red flag that follows the business.
- Lost trust with the board and investors. The tax provision is often the number the board understands least and therefore relies on most. When it turns out to be wrong, the board's confidence in the whole finance function drops — and that erosion of trust is far harder to rebuild than the number is to fix.
- Questions from investors and financiers that you can't answer cleanly. Private equity, banks and lenders read the tax note. A provision that doesn't reconcile, an effective tax rate no one can explain, or a deferred tax asset the auditor wrote down all generate exactly the questions a business least wants during a funding round or covenant review — the same scrutiny that tax due diligence applies — and being unable to answer them cleanly costs credibility at the worst possible moment. A tax position that looks uncontrolled is priced as a risk.
- Playing catch-up, every year. Provision errors rarely stay in one year. A missed timing difference or a misstated deferred tax balance carries forward, so next year's provision starts from a wrong opening position — and someone has to unpick it before they can even begin. A problem ignored at one year end becomes a bigger problem, under more time pressure, at the next. It is also the most common reason the provision delays the year-end close.
None of these are hypothetical worst cases. They are the ordinary downstream consequences of a provision prepared late, without the reconciliation built and the judgements documented. That is precisely why the discipline described above — year-round schedules, judgements made and evidenced at the time, a provision built for the auditor — is worth the effort: it is a great deal cheaper than the alternative.
What the board should see
The provision is not just an audit deliverable; it is a governance one. Directors carry responsibility for the accounts they sign, and the tax provision is often the most technically opaque number in them. A board shown only the final figure is not being given what it needs.
A well-presented provision gives the board the effective tax rate and why it differs from 25% (here, 22.8%, driven by loss utilisation), the material judgements taken (the loss recognition position across two years), the key risks and how they are provided for, and any uncertainty that could move the number. That is what allows directors to discharge their responsibility knowingly rather than by signature alone — our guide to what the board should see in the tax provision covers this in full — and it is increasingly what investors and lenders expect to see evidence of, as part of a wider tax governance framework.
Getting it right — the year-round approach
The fix for a provision that goes wrong every year is to stop treating it as a year-end event. The groups that have no trouble with it maintain the deferred tax schedule through the year rather than reconstructing it at year-end; resolve judgement calls (loss recognition, uncertain positions) before the deadline pressure; build the reconciliation as they go; and have someone who owns the provision as a defined responsibility.
For a business without an in-house tax team, that ownership is exactly what an Outsourced Head of Tax provides — the provision prepared properly, the journals and note ready, the auditors handled with the kind of exchanges above, and the board given what it needs, on a retained basis without the cost of a full-time hire. It is often the engagement that begins a longer relationship: the year-end problem is acute enough to prompt action, and once the provision is under control, the same judgement is valuable across everything else the business faces — including the added complexity that arises for groups with an overseas parent.
Frequently asked questions
Is the tax provision the same as the corporation tax return?
No. The return is filed with HMRC after year-end; the provision is the tax figure in the financial statements at year-end. They are related but prepared differently, and a business can get the return right while getting the provision wrong.
Why do auditors query the tax provision so often?
Usually because the provision was prepared without anticipating scrutiny — the reconciliation isn't built, the deferred tax doesn't reconcile, or the judgements aren't documented. A provision prepared for the auditor from the start, with judgements tied to evidence, avoids most queries.
What is the most common deferred tax error?
Recognising a deferred tax asset on carried-forward losses that fails the "probable future profits" test, which the auditor then writes down. Missed timing differences are a close second.
How do you justify not recognising a deferred tax asset on losses?
By reference to whether future taxable profits are sufficiently probable at the balance sheet date, documented at the time — not reconstructed later. Consistency of that judgement year to year is what auditors test.
What happens if the tax provision is wrong?
Consequences range from a delayed or modified audit opinion to a prior-year restatement, lost trust with the board, and difficult questions from investors and lenders who read the tax note. Errors also carry forward, so next year's provision starts from a wrong position — meaning the problem compounds rather than resolves.
Do we need to hire someone in-house?
Not necessarily. An Outsourced Head of Tax can own the provision, prepare the journals and note, handle the auditors and report to the board on a retained basis, giving a growing group senior tax judgement without a full-time cost.

