Notification of uncertain tax treatments: why it’s time to take notice

L-day 2021 was a relatively muted affair with less draft legislation than might have been expected and little in the way of surprises. This is no bad thing not least because it gives space to consider important tax compliance measures such as the new rules on notifications of uncertain tax treatments which might otherwise have been overlooked in favour of more eye-catching substantive announcements. The new rules will apply in relation to uncertain tax treatments reflected in returns filed on or after 1 April 2022 and so they are potentially relevant to transactions and other activities occurring now. Businesses and advisers will want to start familiarising themselves with the legislation to assess what if anything they will need to change about their existing compliance processes. Draft guidance on the...