HMRC recently published its draft guidance on the uncertain tax treatment regime. It was hoped it would clarify the interpretation of the vaguer aspects of the statute, making it easier for taxpayers to meet their compliance obligations. Unfortunately, the guidance offers limited practical assistance and suggests HMRC will be taking a strict view on when a notification is required and the detail required to make such a notification valid. Whilst the consultation on the draft legislation and guidance has now closed, taxpayers should continue to engage with HMRC. The regime is improved from earlier versions, but there is still work to do.
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HMRC recently published its draft guidance on the uncertain tax treatment regime. It was hoped it would clarify the interpretation of the vaguer aspects of the statute, making it easier for taxpayers to meet their compliance obligations. Unfortunately, the guidance offers limited practical assistance and suggests HMRC will be taking a strict view on when a notification is required and the detail required to make such a notification valid. Whilst the consultation on the draft legislation and guidance has now closed, taxpayers should continue to engage with HMRC. The regime is improved from earlier versions, but there is still work to do.
If you are not a subscriber, subscribe now to read this content.
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