Uncertain Tax Treatments by Large Businesses Manual

UTT17000 - Penalties: contents

We expect there to be strong compliance with the uncertain tax treatment (UTT) provisions. HMRC’s Large Business Customer Compliance Managers (CCMs) and Mid-sized Business Caseworkers will consider this as part of their overall risk assessment of companies. However, if there are failures penalties will be chargeable.

1. UTT17100

   Circumstances in which a penalty is chargeable overview
2. UTT17150

   In what circumstances is discretion exercised overview
3. UTT17200

   Types of penalty
4. UTT17300

   In what circumstances is a penalty chargeable
5. UTT17350

   In what circumstances is discretion exercised
6. UTT17400

   Assessing a penalty: contents
7. UTT17500

   Uncertain Tax Treatment Appeals