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Delay to uncertain tax treatment proposal

Jo Crookshank (Simmons & Simmons) welcomes news of the delay in the implementation of these notification proposals, and explains what’s needed to deliver a more workable result.

The government has announced that it will delay bringing forward legislation to implement its proposal to require large businesses to notify any uncertain tax treatment in their filing position to HMRC. In a written ministerial statement made on 12 November FST Jesse Norman MP announced that implementation of the proposal will be delayed until April 2022. This is to allow more time ‘to get the policy and legislation right following the recent consultation including through further engagement with stakeholders and will give affected businesses more time to prepare for the change.’

The announcement follows indications from HMRC that government has been listening to feedback on its consultation and that HMRC has accepted in principle that the original proposal was...

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