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Notifying HMRC of uncertain tax treatments: transparency or confusion?

Ian Hyde and Matthew Greene (Osborne Clarke) examine the government’s plans to require large businesses to notify HMRC of uncertain tax treatments they have adopted after April 2021.

One of the proposals contained in the Budget is a requirement for large businesses to tell HMRC when they have adopted an ‘uncertain tax treatment’. HMRC has launched a consultation on the new measures and it is expected that the notification requirement will be contained in Finance Bill 2020/21 and apply to uncertain tax treatments reflected in returns filed after April 2021.

Why does HMRC want these measures?

One of the key metrics which HMRC monitor is the so-called tax gap: the difference in a given year between what HMRC considers to be the right amount of tax and the amount HMRC actually collects.

The UK tax system is notoriously complex and it is inevitable that there will...

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