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Notification of uncertain tax treatments: why it’s time to take notice

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The government is pressing ahead with legislation requiring large businesses to notify uncertain tax treatments. The proposals have been improved on following two rounds of consultation with the seven triggers for notification reduced to three, although a new ‘sweeper’ trigger is potentially very wide. These new rules will still create a significant compliance burden and, for some businesses, will apply to transactions entered into now. 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.

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