The government have published a consultation 'Technical consultation: Uncertain tax treatment', which invites responses in relation to newly drafted HMRC guidance for the Uncertain Tax Treatment legislation which will come into effect on 1 April 2022.

The Uncertain Tax Treatment (UTT) rules are designed to promote early identification and disclosure of tax uncertainties by large businesses. This will be through notification to HMRC of any returns submitted that contain an 'uncertain number'. An uncertain amount is one that is arrived at through a tax treatment different to the interpretation of the law by HMRC.

Companies or partnerships fall into the UTT regime where they satisfy:

  • A UK turnover above £200 million.
  • UK balance sheet total over £2 billion.

The draft guidance was originally issued in August 2021 and external stakeholder feedback has already been received. This feedback has been used in drafting the second version of the guidance, which is now subject to this technical consultation.

The guidance will be published in its final version by 28 February 2022 as the notification requirement takes effect on 1 April 2022.

To respond to the consultation, email This email address is being protected from spambots. You need JavaScript enabled to view it..

Useful guides on this topic

Call for evidence: Basis Period Reform and Uncertain Tax Treatment
The House of Commons' Finance Bill Sub-Committee has issued a call for evidence seeking views on the draft legislation published in Finance Bill 2021-22 for the Reform of Basis Periods and the Uncertain Tax Treatment provisions.

Uncertain Tax Treatment guidance released
HMRC have released guidance to accompany the draft legislation that they released which covers Uncertain Tax Treatment (UTT) for large businesses.

Notification of uncertain tax treatments by large businesses: consultation responses
The government intends to have large businesses notify HMRC when uncertain tax treatments have been adopted within a tax return. The consultation is now closed and a summary of the responses has been published.

External links

To read the guidance, see: Technical consultation: Uncertain tax treatment


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