Steven Porter and Abigail McGregor (Pinsent Masons) consider the UTT regime after two years of operation.
1. When does a company need to make an Uncertain Tax Treatment notification?
Since 1 April 2022 following the introduction of FA 2022 Sch 17 all large businesses both corporate and partnerships have been required to notify HMRC when they submit a return which includes an ‘uncertain amount’. A large business means one which exceeds either or both size limits being an annual turnover of £200m or a balance sheet of £2bn.
An uncertain amount means either:
a provision has been recognised in the accounts to reflect the probability that a different tax treatment will be applied to a transaction to which the amount relates; or
the tax treatment applied in arriving at the amount relies (wholly or in part) on an interpretation or application of the law that is not...
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Steven Porter and Abigail McGregor (Pinsent Masons) consider the UTT regime after two years of operation.
1. When does a company need to make an Uncertain Tax Treatment notification?
Since 1 April 2022 following the introduction of FA 2022 Sch 17 all large businesses both corporate and partnerships have been required to notify HMRC when they submit a return which includes an ‘uncertain amount’. A large business means one which exceeds either or both size limits being an annual turnover of £200m or a balance sheet of £2bn.
An uncertain amount means either:
a provision has been recognised in the accounts to reflect the probability that a different tax treatment will be applied to a transaction to which the amount relates; or
the tax treatment applied in arriving at the amount relies (wholly or in part) on an interpretation or application of the law that is not...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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