Notification of uncertain tax treatments: HMRC's final guidance

HMRC has published the final guidance on the notification of uncertain tax treatment by large business after considering all the feedback and using it to improve the quality of the guidance, offering further clarity on how the new regime will apply and assisting taxpayers in managing their obligations.

In a client briefing, EY observed that: ‘the contents of the final guidance appear to be very similar to that draft guidance, although additional clarification is provided on certain points. For example, the published guidance specifies that “Trigger 2” (which brings a treatment potentially within the scope of the rules if it is contrary to HMRC’s “known position”) should be applied as at the date on which the relevant return is filed.’