Notification of uncertain tax treatments: round two

As part of the wider publication of consultation documents on ‘tax day’ HMRC has released the second round of its consultation on the notification of uncertain tax treatments. Interested parties have until 1 June to provide a response.

The government intends to introduce legislation implementing the regime in Finance No.2 Bill 2021/22 with effect for tax positions taken in any returns due to be filed after April 2022. Subject to any further delay this means that corporation tax positions being taken today fall within the new regime. In addition it is implied by the consultation that some pre-existing ongoing tax treatments will also need to be notified even when the treatment in question has been applied for many years.

What is the purpose of the proposal?

The...