HMRC has published the
final guidance on the notification of uncertain tax treatment by large business
after considering all the feedback and using it to improve the quality of the
guidance, offering further clarity on how the new regime will apply and assisting
taxpayers in managing their obligations.
In a client briefing, EY
observed that: ‘the contents of the final guidance appear to be very similar to
that draft guidance, although additional clarification is provided on certain
points. For example, the published guidance specifies that “Trigger 2” (which
brings a treatment potentially within the scope of the rules if it is contrary
to HMRC’s “known position”) should be applied as at the date on which the
relevant return is filed.’
HMRC has published the
final guidance on the notification of uncertain tax treatment by large business
after considering all the feedback and using it to improve the quality of the
guidance, offering further clarity on how the new regime will apply and assisting
taxpayers in managing their obligations.
In a client briefing, EY
observed that: ‘the contents of the final guidance appear to be very similar to
that draft guidance, although additional clarification is provided on certain
points. For example, the published guidance specifies that “Trigger 2” (which
brings a treatment potentially within the scope of the rules if it is contrary
to HMRC’s “known position”) should be applied as at the date on which the
relevant return is filed.’
