Large Businesses - notification of uncertain tax treatments
From April 2022, a new regime will require large businesses to notify HMRC of uncertain tax treatments, so that HMRC becomes aware of the adoption of a tax treatment that is not in accordance with HMRC’s known position at an earlier stage.
From April 2022, a new regime will require large businesses to notify HMRC of uncertain tax treatments, so that HMRC becomes aware of the adoption of a tax treatment that is not in accordance with HMRC’s known position at an earlier stage.
The requirement to notify HMRC of uncertain tax treatment applies to relevant companies, LLPs and partnerships (referred to as “entities” throughout) in respect of returns due to be filed on or after 1 April 2022.
Notification of uncertain tax treatments is only required in respect of corporation tax, partnership, PAYE or VAT returns.
The new rules have not yet been legislated but are expected to be part of Finance Act 2022. The outline of the rules provided below is based on the draft legislation and HMRC’s most recently published guidance which is currently in draft form but expected to be finalised by the end of the month.
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