Notification of uncertain tax treatments: round two

Last year the government consulted on plans to require large businesses to notify HMRC of uncertain tax positions. The proposals were met with criticism from respondents, largely owing to the relatively low threshold for reporting and the subjective proposed test for ‘uncertain’ treatments, which required taxpayers to predict whether HMRC would challenge a position knowing all of the relevant facts (even if that challenge was unlikely to be successful). The second round of the consultation seeks to address these concerns through raising the reporting threshold and setting out more prescriptive tests for notification. The consultation closes 1 June 2021.