Consultation on uncertain tax treatment technical guidance

HMRC has launched a consultation seeking views on the technical guidance on the requirement for large businesses to notify HMRC when they take an uncertain tax position.

The initial draft technical guidance published in August 2021 explained how HMRC will interpret and apply the uncertain tax treatment legislation. In light of the responses received it has published a second version of the guidance. This explains the aim of the new regime - to promote early identification and disclosure of tax certainties by large businesses. It also has examples to show that when a company is a member of a group its UK turnover and UK balance sheet totals should be aggregated with other 51% subsidiaries for the purposes of determining whether the large business is within scope.

In addition it states which taxes are affected namely income tax corporation tax and VAT and notification criteria.

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