HMRC consultation: Notification of uncertain tax treatment by large businesses

29 June 2020

HMRC has published a consultation which aims to collate feedback and opinions on a new proposed notification regime to identify particular areas of uncertain tax treatment. It is hoped that this will improve HMRC’s ability to pinpoint issues where larger businesses have taken a different legal interpretation to HMRC’s view, which in some scenarios, HMRC may seek to challenge.

The consultation opened on 19 March 2020 and was initially due to close on 27 May 2020, but due to the disruption caused by coronavirus, the end date has been extended to 11.45 pm on 27 August 2020. HMRC is still, however, asking for early responses from stakeholders, where possible.

The consultation is primarily concerned with views on the method and detail of the notification, and also on specific areas of uncertain tax treatment. The notification is due to come into effect from April 2021.

Anybody wishing to respond to the consultation should email:

[email protected]


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