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Tax and the City review for February 2022

Speed read
Revised draft guidance on large business notification of uncertain tax treatment encourages early engagement with HMRC and elaborates on what constitutes HMRC’s ‘known position’. The Court of Appeal in Embiricos agrees with the Upper Tribunal that HMRC cannot be required to give a partial closure notice without quantifying the tax due to give effect to HMRC’s conclusion that Mr Embiricos was domiciled in the UK. The UK government consults on the implementation of the global minimum tax rules. Changes are to be made to allow UK securitisations and insurance-linked securities arrangements to operate more effectively.

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