Consultation outcome

Notification of uncertain tax treatment by large businesses

From:: HM Revenue & Customs
Published: 19 March 2020
Last updated: 23 March 2021 — See all updates

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Notification of uncertain tax treatments by large businesses - summary of responses

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Notification of uncertain tax treatments by large businesses - summary of responses (open document format)

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Detail of outcome

The proposal was designed to improve HM Revenue and Customs’ ability to identify issues where businesses have taken an uncertain tax treatment in a return.

This consultation sought views on how the regime should operate, in particular, from parties that would be most impacted by these changes.

We received 55 written responses and held 14 meetings with businesses, individuals and representative agents and bodies.

The government has considered these responses and published a follow-up consultation to further develop this policy. This will run from 23 March to 1 June 2021.

Original consultation

Consultation description

This consultation was published on 19 March and was due to close on 27 May. We are grateful for the responses we have already received. The government recognises that many sectors with an interest in this policy are affected by COVID-19. We want to give all stakeholders time to submit their views, so we have extended the consultation. The closing date is now 27 August 2020 (11.45pm). However, we encourage early responses from stakeholders, where possible, to support our ongoing consideration of this policy.

The proposal is designed to improve HM Revenue and Customs’ ability to identify issues where businesses have adopted a different legal interpretation to the view of HM Revenue and Customs.

This requirement will help to reduce tax losses caused by businesses adopting tax treatments that do not stand up to legal scrutiny. This proposal is not intended to suggest that HMRC’s interpretation is always correct or that a difference in legal interpretation is avoidance or evasion.

This consultation seeks views on the method and detail of the notification and particular areas of uncertain tax treatment.

The notification requirement is due to come into effect from April 2021.

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