Consultation: Extend Notification of Uncertain Tax Treatment (UTT) regime
The consultation proposes extending UTT to capture more legal interpretation uncertainties and seeks views on widening scope and implementing changes.
This consultation sets out government proposals to extend and enhance the Uncertain Tax Treatment (UTT) regime. It aims to reduce the legal interpretation portion of the tax gap by requiring more legal interpretation uncertainties to be notified to HMRC.
Proposed changes include widening the scope of UTT to additional taxes — such as Stamp Duty Land Tax (SDLT), National Insurance contributions (NICs), the Construction Industry Scheme (CIS), Inheritance Tax (IHT) and Capital Gains Tax (CGT) — and bringing wealthy individuals and trusts within scope where legal interpretation uncertainties give rise to a tax advantage over £5 million.
The consultation also seeks views on introducing an additional trigger to capture uncertainties not currently notifiable, improving consistency and early visibility of issues. This consultation invites feedback to support the design and implementation of future legislation, and to help us understand its practical impacts.