Notification of uncertain tax treatment regime

With effect for company partnership PAYE or VAT returns due to be filed on or after 1 April 2022 large businesses are obliged to notify HMRC if the return includes an amount that is uncertain. The legislation applies to qualifying companies and partnerships which are those with a UK turnover of more than £200m or a UK balance sheet total of more than £2bn. These limits also apply to groups but HM Treasury can make regulations to provide that a company meeting specific conditions is not a qualifying company for these purposes. An amount is uncertain if it is more than £5m (unless varied by regulations) and the accounts include a provision to reflect the probability that a different tax treatment will be applied to the transaction or that an interpretation or application of the law is not in accordance with that of HMRC. Unless...