Notification of uncertain tax treatment by large businesses - second consultation
Download the full outcome
Detail of outcome
The proposal was designed to improve HM Revenue and Customs’ ability to identify issues where businesses have taken an uncertain tax treatment in a return.
This second consultation ran from 23 March to 1 June 2021 and built on the views received to the previous consultation. It particularly sought views on:
- the definition of uncertain tax treatment
- the threshold for notification
- exclusions from the requirement to notify
- the proposed penalty for non-compliance
We received 34 written responses and held 15 meetings with agents and representative bodies. The government appreciates the feedback received and is publishing draft clauses for consultation.
Original consultation
Consultation description
The proposal is designed to improve HM Revenue and Customs’ ability to identify issues where businesses have taken an uncertain tax treatment in a return.
This requirement will help to identify and reduce tax losses caused by delays in identifying and resolving disagreements in how the law should be interpreted. This proposal is not intended to suggest that HMRC’s interpretation is always correct or that a difference in legal interpretation is avoidance or evasion.
This is the second consultation on this proposal and builds on responses to the previous consultation, which ran from 19 March to 27 August 2020. We are grateful for the responses we have received to that consultation.
Particularly, we are seeking views on:
- the definition of uncertain tax treatment
- the threshold for notification
- exclusions from the requirement to notify
- the proposed penalty for non-compliance
The notification requirement is due to come into effect from April 2022.
Documents
Last updated 20 July 2021 + show all updates
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Published consultation outcome and summary of responses.
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First published.