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.

The consultation on the 'Notification of Uncertain Tax Treatments by Large Businesses' ran from 19 March to 27 August 2020 (extended due to Covid-19). The government aims to improve HMRC’s ability to identify issues where businesses have taken an uncertain tax treatment in a return by requiring notification. It is intended that this requirement will have effect from April 2022.

The consultation asked 19 questions on how the regime would operate and the impact on business, summarised as follows:

The government held 14 meetings and received 55 written responses. A summary of the responses is as follows:

Based on the responses, the government has issued a second consultation to further understand the issues raised. This consultation will consider:

This second consultation will close on 1 June 2021 at 11.45pm. Responses should be sent to This email address is being protected from spambots. You need JavaScript enabled to view it..

Useful guides on this topic

Penalties: Senior Accounting Officers  
The Senior Accounting Officer (SAO) of a large company is required under Schedule 46 FA 2009 to ensure the existence of, and report on, the appropriateness of their tax accounting arrangements. Penalties are charged in the event of failures.

External Links

Consultation: Notification of Uncertain Tax Treatments by Large Businesses

Notification of Uncertain Tax Treatments by Large Businesses: Summary of responses

Second consultation: Notification of Uncertain Tax Treatments by Large Businesses


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