Research and analysis

Notification of Uncertain Tax Treatment policy evaluation report

Published 17 July 2025

1. Executive Summary

The Uncertain Tax Treatment policy requires larger businesses to notify HMRC when they adopt a tax position that is uncertain and exceeds certain thresholds (section 2). It aims to increase transparency and speed discovery and provide resolution sooner of such cases, thereby reducing the legal interpretation tax gap and meeting HMRC’s strategic objectives to collect the right tax and to make it easier to follow the rules.

The Uncertain Tax Treatment policy came into effect from 1 April 2022. Within the first 2 years, businesses submitted Uncertain Tax Treatment notifications for tax interpretations unknown to HMRC (section 3). This decreased the time it took to discover uncertain tax positions. Uncertain Tax Treatment notifications represented large tax advantages (median of £15 million per case). As a result, the Uncertain Tax Treatment policy met its primary objectives of increasing tax position transparency and bringing uncertainties to HMRC’s attention earlier.

This evaluation draws on the results of the Large Business Survey, and a commissioned social research study delivered by the National Centre for Social Research (NatCen) on HMRC’s behalf. We also draw on Uncertain Tax Treatment notifications, but sample sizes are small and cases are highly specific; as such, generalising to the wider population must be done with caution.

This evaluation of the Uncertain Tax Treatment policy addresses concerns that it would be disproportionately burdensome (for example, raised by the House of Lords Economic Affairs Committee as well as other stakeholders). Evaluating the Uncertain Tax Treatment policy within three years of its implementation is challenging (section 3 and annex) because such cases typically take many years to resolve due to the complex tax arrangements and legal disputes. As such, the period allotted for the evaluation is shorter than the period required for addressing legal uncertainties. As a result, administrative burden impact and only early indicators of changes in behaviour can be assessed.

All survey sources and interviews indicated that one-time setup costs and the continuing costs of complying with the Uncertain Tax Treatment policy are considered small and reasonable by the majority of participants (Large Business Survey 2022: only 5% disagreed, see section 3); this aligns with expectations set out in the Tax Information and Impact Note. Businesses that identified themselves as low risk and already actively communicating Uncertain Tax Treatments reported the costs as low. As a result, the Uncertain Tax Treatment policy did not significantly impact businesses that had transparent tax treatments (see section 3).

Businesses interviewed in NatCen research indicated they already engaged with HMRC and were unlikely to change their behaviour because they were already notifying HMRC of any uncertainties via Customer Compliance Managers (see section 3).

Costs to HMRC have been minimal and businesses reported that the Uncertain Tax Treatment policy established a formal process, that had not existed previously (see section 3), to notify HMRC of uncertainties.

Customers were concerned delays in communications with Customer Compliance Managers might be exacerbated by notifications of Uncertain Tax Treatments but were unsure if delays were a general issue for HMRC (see section 3); delays are an ongoing issue raised in the Large Business Survey results for multiple years and unrelated to the Uncertain Tax Treatment policy. Additional administrative burdens are generally not reported by customers that actively avoid adopting uncertain tax positions. This indicates that any likely administrative burden due to the Uncertain Tax Treatment policy should mainly be experienced by businesses adopting uncertain tax positions and the policy should only impact segments of the population that it is designed to target.

In conclusion, evidence from Uncertain Tax Treatment notifications as well as research with businesses indicates that the Uncertain Tax Treatment policy is meeting its objectives of changing businesses’ behaviour by increasing tax position transparency for some who were not transparent and promoting equality for those who already were transparent. As a result, the Uncertain Tax Treatment policy is contributing to reducing the legal interpretation portion of the tax gap.

2. Introduction

HMRC implemented the Notification of Uncertain Tax Treatment policy to reduce the legal interpretation portion of the tax gap by requiring large businesses to bring uncertain tax interpretations to HMRC’s attention as soon as certain triggers are met. This notifies HMRC of tax uncertainties requiring clarification and resolution more quickly, and thereby avoids the lengthy time normal compliance activities take to discover uncertainty.

Legal interpretation tax losses contribute to the tax gap and arise when the taxpayer takes a different view from HMRC of how the law should be interpreted or applied, resulting in a different tax outcome. Different tax treatments can result in too little tax being paid if the treatment is based upon an incorrect interpretation of the law.

HMRC cannot identify all legal interpretation issues from returns. Legal interpretation disputes can take years to identify (meaning, time taken to discover) and resolve. Previously, HMRC has identified Uncertain Tax Treatments in instances too long after their use to appropriately resolve them (for example, VAT cases have a limited timeframe to identify and resolve). Resolution is often achieved through litigation, which is costly for both taxpayers and HMRC. Longstanding legal interpretation disputes cause uncertainty for HMRC and taxpayers and undermine trust in the tax system.

The Uncertain Tax Treatment policy aims to highlight and resolve legal interpretation differences by encouraging more businesses to follow best practice and discuss areas of uncertainty with HMRC before they submit their returns or, if necessary, through Uncertain Tax Treatment notification.

Thresholds and triggers for notifying

Under the Uncertain Tax Treatment policy, tax interpretations for Corporation Tax, VAT, or Income Tax (via Self-Assessment or payroll PAYE) are classified as uncertain if the tax treatment meets one (or both) of 2 legislative criteria:

• a provision is made in the accounts for the uncertainty (the ‘provision’ trigger).

• the tax treatment applied is not in accordance with HMRC’s known position (the ‘known position’ trigger).

Under the Uncertain Tax Treatment policy, businesses must notify HMRC if the tax advantage exceeds a £5 million threshold. The Uncertain Tax Treatment policy applies to companies and partnerships with a turnover exceeding £200 million or a balance sheet total of more than £2 billion or both. As a result, the target population includes businesses within both Large Business and Mid-Sized Business groups. The proportion of the population of businesses this policy applies to that had Uncertain Tax Treatments in the past and hadn’t communicated them to HMRC is small, however the monetary value of those cases was large. Therefore, the Uncertain Tax Treatment policy was aimed at addressing the largest tax advantages and therefore have the greatest long-term impact on reducing the tax gap. The regime applies to all returns filed on or after 1 April 2022. This evaluation report summarises the findings of the evaluation completed between April 2022 and March 2025.

Policy objective

The overarching policy objective was to contribute towards reducing the legal interpretation portion of the tax gap, which was estimated at £3.9 billion representing 10% of the total tax gap in 2022 to 2023. Of the £3.9 billion legal interpretation portion of the tax gap, approximately 46% was attributed to Large Business.

Legal Interpretation as a proportion of the tax gap has been on a downward trajectory over the period of the tax year 2019 to 2020 to tax year 2022 to 2023, falling from 12% to around 10% (2024 tax gap publication). This reduction is largely attributable to the reduction in the total VAT gap over this period. Since estimates of the VAT gap are particularly volatile, it is important to consider the trend, rather than the year-to-year changes. Multiple factors such as wider fluctuations in the economy and additional compliance activity all affect the tax gap and its yearly revisions. Therefore, it is not useful to use a before and after comparison of the tax gap in determining the success of the Uncertain Tax Treatment policy.

The Uncertain Tax Treatment policy was not expected to eradicate the legal interpretation portion of the tax gap, and therefore the legal interpretation tax gap methodology should not be used in isolation to provide evidence of the legislation’s success.

The Uncertain Tax Treatment policy is intended to help achieve this wider policy objective of reducing the tax gap by meeting the following policy aims (see evaluation plan):

• enable earlier identification of potential legal interpretation disputes – earlier identification would enable the matter to be settled and clarified earlier in guidance or case law, which would increase certainty to all taxpayers.

• promote equality with businesses that are already open and transparent with HMRC about uncertainties.

• assess the correct tax amount where the different interpretation has resulted in too little tax being collected.

Therefore, the Uncertain Tax Treatment policy is aimed at changing the behaviour of businesses that adopt uncertain tax positions to gain a tax advantage, by ensuring those businesses are transparent and thereby allowing HMRC to provide clarity.

Evaluation aims and objectives

The Uncertain Tax Treatment policy was designed to change the behaviour of businesses taking uncertain tax positions by improving their engagement with HMRC without overly impacting businesses that don’t take such positions; this increase in engagement should contribute to reducing the tax gap in the long-term. We assessed available data for evidence of behavioural change that indicate improved engagement. We also assessed administrative burden data to identify the impact of complying with the Uncertain Tax Treatment policy.

This evaluation assessed three broad themes of taxpayer-HMRC engagement:

• tax transparency – the effectiveness of the Uncertain Tax Treatment policy in encouraging businesses to engage with HMRC on uncertain tax positions

• timely engagement – the effectiveness of the Uncertain Tax Treatment policy in speeding up time to discover the adoption of uncertain tax positions, through earlier engagement from taxpayers

• HMRC clarity – the ability for HMRC to provide clarification on Uncertain Tax Treatments when raised

The evaluation assessed these themes considering three areas of impact (see Tax Information and Impact Note and evaluation plan):

• administrative burden – impact on businesses that meet Uncertain Tax Treatment policy size and turnover criteria

• customer service – impact on HMRC when administering the Uncertain Tax Treatment policy

• effectiveness – impact that will lead to reducing the legal interpretation proportion of the tax gap

In line with the above themes and areas of impact, the original evaluation plan identified possible beneficial impacts including (see evaluation plan):

• increased receipts and reduced losses caused by legal interpretation issues

• increased certainty for customers around their tax affairs

• increased efficiency and resource saving for customers seeking certainty from HMRC

• increased efficiency and resource savings for HMRC in addressing legal interpretation issues

The original evaluation plan also identified possible negative impacts in line with the above themes and areas of impact including (see evaluation plan):

• increased administrative burden that complying with the Uncertain Tax Treatment policy places on the businesses within scope

• increased demand on HMRC resources to provide the existing level of customer service, due to potential increased customer contact to discuss uncertainties and process notifications

• that a small number of businesses in scope that do not have a Customer Compliance Manager still have access to the equivalent level of service as those with a Customer Compliance Manager

This evaluation also aimed to establish the counterfactual, which is ‘what would have happened in the absence of the Uncertain Tax Treatment notification policy?’. The original evaluation plan identified that the counterfactual could only be estimated and could not be directly measured because it is difficult to separate the influence of the Uncertain Tax Treatment policy from other influencing factors, such as other changes to online guidance or wider policies more generally. Here we addressed this by identifying Uncertain Tax Treatment notifications that HMRC was not previously aware of and were only notified due to the Uncertain Tax Treatment policy.

Evaluation evidence sources

This evaluation synthesises three sources of evidence:

• HMRC data – internal data held by HMRC, including Uncertain Tax Treatment notification data and HMRC case management data. Uncertain Tax Treatment notifications were context specific and therefore difficult to confidently generalise. Additionally, litigation processes for legal interpretation cases take several years to resolve and therefore will not be confidently known for some time. As such, quantitative estimates of the impact of the Uncertain Tax Treatment policy are not possible at this time.

• Large Business Survey 2022 – a survey commissioned by HMRC and conducted by IFF Research. This quantitative telephone survey included 548 Large Businesses served by the Large Business Directorate (representing 31% of the population) and was conducted between September 2022 to January 2023. A qualitative ‘follow-up’ phase, consisting of 30 in-depth interviews with respondents from the main survey, was conducted between January and February 2023.

• external qualitative research data (NatCen report) – interviews conducted with businesses who meet the threshold for the Uncertain Tax Treatment policy. NatCen carried out 18 online depth interviews with a sample of large businesses eligible for interaction with the Uncertain Tax Treatment policy. NatCen carried out the fieldwork in April and May 2024 by interviewing individuals in senior tax positions within their businesses.

3. Detailed findings

Uncertain Tax Treatment notifications overview

HMRC received Uncertain Tax Treatment notifications highlighting uncertain tax positions that were previously unknown and therefore the policy has already had behavioural impact on the target population. The total Uncertain Tax Treatment notifications summed to more than £900 million at the end of March 2025, with a median value of £15 million. The Uncertain Tax Treatment notifications received represent both recent and historic uncertain tax positions depending on the trigger mechanism (known position or provision, see section 2). However, it is not currently possible to calculate the impact of Uncertain Tax Treatment policy on collecting historic totals of the legal interpretation tax gap.

Uncertain Tax Treatment notifications include submissions from Mid-Sized Business, indicating both Large Businesses and Mid-Sized Businesses are successfully using the system. These include a number of notifications of uncertain tax positions that were not previously known about to HMRC, the details of which cannot be shared for disclosure reasons. As such, the Uncertain Tax Treatment policy has successfully led to the declaration of uncertain tax positions that were not previously raised with HMRC.

A number of aspects could not be directly assessed due to the timeframe of the evaluation and the time these cases take to conclude (see table in annex for overview of critical success factors).

Tax transparency – business engagement with HMRC

Businesses reported engaging readily with HMRC already (NatCen report section 4.1, Large Business Survey 2022 section 10.14). Just over a third (36%) of businesses agreed that the Uncertain Tax Treatment policy requirement has made them more likely to actively engage with HMRC to obtain certainty on uncertain tax treatments (Large Business Survey 2022 figure 10.1). The same proportion (36%) neither agreed nor disagreed with the statement, and around a fifth (22%) disagreed. Amongst the businesses that did not agree that the Uncertain Tax Treatment policy notification requirement had made them more likely to actively engage with HMRC on uncertain tax treatments, most typically attributed this to the view that they already adequately engaged with the department to get certainty (54%). The next most common view returned was that the business was unlikely to have uncertain tax treatments as per the requirement (27%, see Large Business Survey 2022 figure 10.2). This was supported in the Large Business Survey 2022 follow up qualitative interviews (Large Business Survey 2022 section 10.15), where many businesses that did not agree with this statement indicated they gave this response because they already engage with HMRC when they have an uncertain tax treatment.

Similar results were returned in the external social research interviews (NatCen report sections 4.2 and 4.3). Interviewed businesses indicated they identified themselves as risk adverse and cautious, so were unlikely to change their behaviour as they already readily engaged with HMRC on any uncertainties. Some also thought they were unlikely to reach the notification thresholds. Typically businesses felt that the Uncertain Tax Treatment policy was also a useful tool to raise uncertainties with the business’s Customer Compliance Manager. Social research also highlighted that businesses that were already transparent in their approaches to tax positions and communicating with HMRC were making use of the exemption process as they had previously notified HMRC of their tax positions.

NatCen research indicated that businesses felt those adopting uncertain tax positions might now avoid them because of the requirement to then engage with HMRC, and such businesses would likely wish to avoid discussion with HMRC at all so as not to draw attention (NatCen report section 4.5). However, no participants of the NatCen research indicated that the businesses they represented were in such a position.

An additional impact found by external research was that the Uncertain Tax Treatment policy might make businesses prepare any Uncertain Tax Treatment positions and defence more extensively thereby reducing the uncertainty (NatCen report section 4.3 and 4.5). Other lines of evidence, such as Large Business Survey 2022, did not go into this detail. This again was a desired outcome of the Uncertain Tax Treatment policy, as businesses establishing a more robust position when they adopt a Uncertain Tax Treatment will help to quicken any investigations.

In line with the findings that engagement was positive or already active, multiple lines of evidence also indicated that the administrative burden costs were reasonable or low (NatCen report section 4.1 and Large Business Survey 2022 section 10.7); this is in line with the expectations set out in the Tax Information and Impact Note. When surveyed, only a small number of businesses disagreed that the costs were reasonable (4% for the one-off cost, and 5% for ongoing costs, see Large Business Survey 2022 figure 10.1). This view was supported by the interviews where costs were reported to be low because they were already compliant and proactively engaged with HMRC. In many instances, this appeared to be because businesses felt they were already engaging with HMRC and their business avoided Uncertain Tax Treatments and uncertainty (for example, NatCen report section 4.1). In this aspect, the Uncertain Tax Treatment policy has performed effectively at ensuring compliant and risk adverse businesses are unaffected, while appropriately impacting businesses that actively are or are considering engaging in Uncertain Tax Treatments; in the long term, this should promote greater tax equality.

In summary, the administrative burden on businesses of increasing tax transparency as a result of complying with the Uncertain Tax Treatment policy notifications is acceptable and/or low for the majority of businesses. Increased engagement work does not have a disproportionate impact on HMRC. The effectiveness of increased tax transparency on reducing the tax gap is difficult to quantify in the short term for legal interpretation cases as these typically take several years to resolve. However, early indications suggest that the Uncertain Tax Treatment policy is having a positive impact in increasing tax transparency.

Timely engagement – notifying HMRC of uncertainties

External research found that businesses continued to take a timely approach to communicating with HMRC (NatCen report section 4.2) and there was potential for improved timeliness of declaration, particularly due to deadline requirements (NatCen report section 4.3). Participants in the external research interviews also reported that the Uncertain Tax Treatment policy provided a prompt to engage with HMRC (NatCen report section 4.3, see also section 4.5 of this report). As such, the Uncertain Tax Treatment policy is a useful tool to raise questions around uncertain tax positions earlier.

Uncertain Tax Treatment notification data indicate that previously unknown uncertain tax positions were reported (note specifics can’t be outlined due to disclosure reasons). These cases where Uncertain Tax Treatments are reported represent increased and timely engagement from the segment of the population that the Uncertain Tax Treatment policy is targeted at.

External research indicated that some businesses wondered if the administrative burden of Uncertain Tax Treatment had delayed communications with their Customer Compliance Manager (NatCen report section 5.2), but they also indicated that it could be for other reasons around resourcing within HMRC (NatCen report section 4.3). Timely engagement with Customer Compliance Managers and delays in communication from Customer Compliance Managers has been a recurring issue mentioned in the Large Business Survey across years (for example, Large Business Survey 2018 sections 5.12 and 6.10). Internal research indicates that delays are due to general resourcing issues and are not the Uncertain Tax Treatment policy related.

No clear additional or unreasonable administrative burden was reported by businesses in carrying out timely engagement, nor was more timely engagement reported as impacting Customer Compliance Manager workloads.

In summary, the additional administrative burden of returning timely Uncertain Tax Treatment notifications appears to be minimal. There are minor additional impacts on HMRC resourcing when tax specialists need to be consulted. However, it appears that the additional minimal burden introduced at timely Uncertain Tax Treatment notification and disclosure will inevitably reduce costly discovery compliance activities and may avoid costly litigation activities in the long term. Although it is currently not possible to calculate how much tax has been protected through the Uncertain Tax Treatment policy, there has already been a behavioural impact that will help address the tax gap as tax uncertainties have been declared earlier where HMRC was previously unaware.

HMRC clarity – guidance provided by HMRC

Businesses interviewed and surveyed typically indicated they had a good relationship with HMRC and their Customer Compliance Managers (Large Business Survey 2022 section 10.14, NatCen report 3.2). They particularly valued a good relationship with their Customer Compliance Managers, and this included timeliness of Customer Compliance Manager response in communications and the clarity Customer Compliance Managers could provide (NatCen report section 5.2).

A small minority in both Large Business Survey 2022 (6% Large Business Survey 2022 sections 10.14 and 10.16) and a participant in the NatCen external research (NatCen report section 4.2) raised that Customer Compliance Managers and HMRC can’t always provide certainty on matters because of a perception that HMRC just provides guidance and may not give legal certainty (Large Business Survey 2022 10.17), so in those cases they would generally rather not communicate with HMRC directly and prefer to communicate with external tax advisors instead.

Participants in the NatCen research also highlighted how the Uncertain Tax Treatment policy formalised and standardised raising issues and this was beneficial to them (NatCen report section 4.4). They also indicated that they viewed the Uncertain Tax Treatment policy as part of a wider suite of policies that worked together to enhance tax compliance for the corporate sector and that this was welcomed by those who wanted to ensure they engaged fully and appropriately with tax compliance and responsibilities (NatCen report section 4.3).

The Uncertain Tax Treatment policy was described as providing a process where a structure or sense of governance did not previously exist. In this way, they reported that formalising the processes adds efficiency to the process without requiring much additional administrative work (NatCen report section 4.4).

Although previously unknown Uncertain Tax Treatments have been declared to HMRC, it is too early to determine how these will result in improved guidance as none have been resolved yet and specifics can’t be provided here for disclosure reasons. This is as expected because legal interpretations issues can take time to complete. A number of Uncertain Tax Treatment notification cases are also highly case specific and it is unclear if they will result in wider guidance changes once closed.

In summary, there is indication that for a small proportion of businesses, the Uncertain Tax Treatment policy is resulting in greater administrative burden and costs, where they prefer to seek external tax advice on issues arising due to Uncertain Tax Treatment rather than raise it with HMRC. The impact on HMRC’s customer service appears to be minimal and the Uncertain Tax Treatment policy is providing structure in an area that needed it. Assessing impact of the Uncertain Tax Treatment policy on the tax gap due to increased clarity from HMRC is difficult to quantify at this early stage, but a number of cases indicate that HMRC will be able to provide clarity sooner than would have been possible if such cases were only left to be found through normal compliance activity.

4. Final evaluation conclusions

The Uncertain Tax Treatment policy has brought uncertain tax positions to HMRC’s attention that it would not have been aware of, and as such has increased engagement and tax transparency for segments of the population that it had not previously managed to reach.

The proportion of the business population that don’t clarify tax uncertainties, nor notify under Uncertain Tax Treatment and do not proactively engage with HMRC appears to be negligible, with the majority of the population reporting they already actively engage with HMRC. However, HMRC will continue compliance work in this area.

Costs to HMRC and businesses stemming from implementing and engaging with the Uncertain Tax Treatment policy are low and in line with previous expectations. It was not possible to establish if businesses who disagreed with the additional administrative burden were the same as those who aren’t proactively engaged with HMRC. However, multiple lines of evidence (such as Large Business Survey 2022, and NatCen report) indicate that the Uncertain Tax Treatment policy had minimal administrative burden or costs for already compliant businesses, and for HMRC.

It is too early to estimate the tax protected by the Uncertain Tax Treatment policy, but it has involved notification of more than £900 million of uncertain tax positions. It is demonstrable that the Uncertain Tax Treatment policy has positively impacted taxpayers’ behaviour in engagement with HMRC and timeliness of reporting.

The Uncertain Tax Treatment policy provides a formalised and more efficient method for raising issues and prompting discussion around uncertainty than was in place previously with minimal impact on HMRC administrative burden.

Annex: In-Depth Assessment of Critical Success Factors

Critical Success Factor (CSF)	Headline results	Impact observed
CSF 1: HMRC raises yield from enquiries, preventing losses pre-return, or through upstream campaigns on issues of legal interpretation	Not able to assess: data too limited to assess and cannot be presented for disclosure reasons; no upstream campaigns conducted or planned.	Unknown
CSF 2: HMRC makes earlier decisions on whether to litigate (or otherwise settle) a legal interpretation issue, bringing yield scoring position forward	Not able to assess: Data too limited to assess and cannot be presented for disclosure reasons. No decisions made on whether to litigate or settle any cases. Baseline data for time taken to discover not available.	Unknown
CSF 3: HMRC communicates decisions on legal interpretation issues earlier	Not able to assess: Data too limited to assess and cannot be presented for disclosure reasons.	Unknown
CSF 4: HMRC improves its technical guidance	No guidance changes have been made yet: At the outset of the project, it was hoped that Uncertain Tax Treatment notifications would provide feedback so that HMRC could update the technical guidance to clarify the HMRC position. Given that the notifications received so far have related to a range of issues, there have been no changes to guidance due to the Uncertain Tax Treatments. Data too limited to assess and cannot be presented for disclosure reasons. New work is planned to research the ‘Guidelines for Compliance’ for Large Business, which is soon to start.	Positive
CSF 5: Customers engage with HMRC earlier on genuine uncertain tax issues	Some positive change observed: Uncertain Tax Treatment notifications have been received that have identified uncertainties that were not previously known. A potential impact of the Uncertain Tax Treatment policy was that the number of non-statutory clearance requests could increase. Non-statutory clearances occur when customers voluntarily seek HMRCs view on the correct tax treatment of a matter prior to a transaction, and HMRC is bound by the view/treatment that is provided to the customer. Since 2019, the number of formal non-statutory clearance requests received has remained stable at about 90-100 per year, although only a few (around 2 per year) had a tax value of over £5 million. NatCen interviews and social research with customers indicate the Uncertain Tax Treatment policy formalises a process that already existed.	Positive
CSF 6: Customers adopt fewer uncertain tax treatments	Not able to assess: Most (86%) of Large Businesses surveyed in the Large Business Survey 2022 said they have a low appetite for risk when it comes to boundary pushing in tax planning, implying that the proportion that may adopt uncertain tax treatments is low.	Unknown
CSF 7: HMRC spends less time risk assessing on legal interpretation issues	No change yet observed: HMRC’s Large Business directorate manage ~2,000 customers and seek to prioritise high-risk transactions through use of data & other insights. With the notifications received so far there has been no measurable impact on the time HMRC spends risk assessing legal interpretation issues.	Neutral
CSF 8: HMRC sustains its level of service to customers, despite increased customer contact	No change yet observed: There was a concern that the Uncertain Tax Treatment policy would lead to discussions of legal interpretation issues taking significantly more time than prior to the introduction of the Uncertain Tax Treatment policy. Few businesses have contacted support teams related to the Uncertain Tax Treatment policy and those businesses have been supported to make notifications.	Positive
CSF 9: Customers have access to the same level of service, regardless of whether they have a Customer Compliance Manager	Mid-Sized Business have successfully submitted notifications: There are a small number of Mid-sized businesses in scope of the Uncertain Tax Treatment policy, which are handled by HMRC’s Wealthy and Mid-sized Business Compliance directorate. These businesses do not have a Customer Compliance Manager that they can communicate with directly, and hence guidance was provided that they should discuss anything related to the Uncertain Tax Treatment policy with the Mid-sized Business Customer Support Team (CST). Few businesses have contacted support teams related to the Uncertain Tax Treatment policy and those businesses have been supported to make notifications.	Positive
CSF 10: Customers rely more on HMRC to obtain certainty on legal interpretation issues	No change yet observed: 36% of businesses surveyed in Large Business Survey 2022 agreed that the Uncertain Tax Treatment policy has made or will make their business more likely to actively engage with HMRC to obtain certainty on legal interpretations of uncertain tax treatments. Whether this has happened is currently unclear.	Unknown
CSF 11: Complying with Uncertain Tax Treatment does not lead to an unreasonable additional administrative burden on customers	Customers generally find costs reasonable: Only a small proportion of businesses surveyed in Large Business Survey 2022 disagreed that the one-off costs (4%) and continuing costs (5%) of complying with the Uncertain Tax Treatment policy requirement were reasonable.	Positive