Notification of uncertain tax treatments: it's time to take notice
The UK government is pressing ahead with legislation requiring large businesses to notify uncertain tax treatments. In the briefing at the link below, Helen Buchanan and John Tolman from our London tax team consider whether the proposals have been improved following two rounds of consultation.
The briefing explains that the seven triggers for notification are reduced to three, although a new ‘sweeper’ trigger is potentially very wide and that these new rules will still create a significant compliance burden and, for some businesses, will apply to transactions entered into now. Consequently, in-scope businesses should start thinking about their processes for identifying uncertain tax treatments and for deciding whether to raise these with HMRC in real time or to disclose them alongside their tax returns.
This briefing was originally published in Tax Journal on 30 July 2021.