The government plans to require large businesses to notify HMRC of uncertain tax treatments they have adopted after April 2021. This will require businesses to consider whether HMRC would be likely to disagree with any tax position worth more than £1m taken in a tax return and, if not, to provide a notification to HMRC. The notification process is to be modelled on that used by the SAO regime, and the new notification requirement will apply to all the same taxes covered by that regime. The proposal throws up a number of issues but the biggest is how to determine what is meant by ‘uncertain’ (where the government intends to draw on international accounting standards). There will be penalties for failure to notify. HMRC is consulting on the new measures and any comments should be provided by 27 May 2020.
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The government plans to require large businesses to notify HMRC of uncertain tax treatments they have adopted after April 2021. This will require businesses to consider whether HMRC would be likely to disagree with any tax position worth more than £1m taken in a tax return and, if not, to provide a notification to HMRC. The notification process is to be modelled on that used by the SAO regime, and the new notification requirement will apply to all the same taxes covered by that regime. The proposal throws up a number of issues but the biggest is how to determine what is meant by ‘uncertain’ (where the government intends to draw on international accounting standards). There will be penalties for failure to notify. HMRC is consulting on the new measures and any comments should be provided by 27 May 2020.
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