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Introduction

For returns due on or after 1 April 2022, certain large companies and partnerships are required to notify HMRC where they adopt an uncertain tax treatment for corporation tax, VAT or income tax (both self assessment and amounts collected via PAYE).

The stated aim of the notification regime is to ensure that HMRC is aware of all cases where a large business has adopted a treatment that is contrary to HMRC’s known position and to bring forward the point at which discussions occur in relation to the tax treatment, thereby reducing what the Government refers to as the ‘legal interpretation tax gap’.

The notification requirement is one part of a series of measures aimed at improving the transparency in the approach large businesses take towards taxation, such as the sanctions for uncooperative behaviours and the requirement to publish tax strategies. For commentary on these, see the What activity is targeted? and Publication of tax strategies by large businesses guidance notes.

The regime applies to large (as defined) companies, partnerships and LLPs including