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UK HMRC Launches Further Consultation on Uncertain Tax Treatment Guidance — Orbitax Tax News & Alerts

UK HMRC has launched an open consultation seeking further views on uncertain tax treatment technical guidance. The guidance concerns the requirement for large businesses to notify HMRC of uncertain tax treatments, which is to come into effect from 1 April 2022. This requirement is provided for as part of the Finance (No.2) Bill 2021-22, which is currently pending in the House of Commons.


Technical consultation: Uncertain Tax Treatment guidance


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

This consultation closes at 11:45pm on 1 February 2022

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.


Technical consultation: Uncertain Tax Treatment (guidance)

Ways to respond

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