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Uncertain tax treatment: highlights from HMRC’s final guidance

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Enactment of Finance Act 2022 on 25 February gave legal effect to the uncertain tax treatment regime. Alongside this, HMRC published its final guidance. It is much improved from the initial draft published last year, including many more practical examples. Furthermore, HMRC’s position on a number of key provisions is now more closely aligned with the text of the statute. Despite this, the uncertain tax treatment regime still poses some fundamental challenges to taxpayers and their compliance processes. Taxpayers are advised to familiarise themselves with the newly enacted regime well in advance of their filing deadlines.

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