Large businesses (corporates and partnerships) will be required to send a specific notification to HMRC if their tax returns contain an Uncertain Tax Treatment (‘UTT’). This new obligation will apply to the legal interpretation of Corporation Tax, Income Tax (including PAYE) and Value Added Tax legislation, for returns that are due to be filed with HMRC after April 2022 and the tax amount involved is more than £5m.
This obligation is the subject of a current HMRC consultation and draft legislation is expected in Summer 2021.
Read the flyer below for more information on the three stage approach to identify whether an obligation to notify may exist, and the seven triggers for identifying an UTT that have been proposed.
