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Notification of uncertain tax treatment by large businesses

From 1 April 2022, businesses must notify HMRC when they take a tax position in their returns for VAT, corporation tax, or income tax (including PAYE) that is uncertain.  This is defined as:

  • A provision has been made in the accounts for the uncertainty; or
  • The position taken by the business is contrary to HMRC’s known interpretation.

Taxpayers need to notify HMRC only where the tax advantage is expected to be over £5m for a 12-month period.

Written 14 January 2022.