Consultation outcome

Technical consultation: Uncertain Tax Treatment guidance

This consultation has concluded

Detail of outcome

We are grateful for the responses we received on the second draft technical guidance for the government’s new policy: Notification of uncertain tax treatment by large businesses.

We have considered all the feedback and have used it to improve the quality of the guidance. We believe it will offer further clarity on how the new regime will apply and assist taxpayers in managing their obligations. The final guidance has now been published.


Original consultation

Summary

We welcome views on the technical guidance for the government’s new policy: Notification of uncertain tax treatment by large business.

This consultation ran from
to

Consultation description

The policy has been designed to reduce the legal interpretation portion of the tax gap by helping HMRC identify more legal interpretation issues at an earlier stage.

An initial draft of the technical guidance was published in August 2021, explaining how HMRC will interpret and apply the Uncertain Tax Treatment (UTT) legislation and to help businesses comply with the new legislative requirements.

We gratefully received contributions from external stakeholders in response to the initial draft and have included these in developing a second version, which we are publishing here for further consultation.

As the notification requirement is due to come into effect from 1 April 2022, we intend to publish the final version of the UTT technical guidance by 28 February 2022.

Documents

Published 18 January 2022
Last updated 28 February 2022 + show all updates
  1. Published an outcome to the consultation, which includes an onward link to the final published guidance.

  2. First published.