Notification of uncertain tax treatment for large businesses
This tax information and impact note sets out a new requirement for large businesses to notify HMRC when they take a tax position in their returns for VAT, Corporation Tax, or Income Tax (including PAYE) that is uncertain.
This measure introduces a new requirement for large businesses to notify HMRC when they take a tax position in their returns for VAT, Corporation Tax, or Income Tax (including PAYE) that is uncertain. Uncertain amounts are defined by reference to 2 criteria: that a provision has been made in the accounts for the uncertainty, or that the position taken by the business is contrary to HMRC’s known interpretation (as stated in the public domain or in dealings with HMRC).
HMRC published an evaluation plan of the uncertain tax treatment policy in December 2022.