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.
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.