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Tax and the City review for February 2022

Revised draft guidance on large business notification of uncertain tax treatment and the Court of Appeal’s decision in Embiricos are some of the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Revised UTT guidance

When the large business notification of uncertain tax treatment rules (UTT) were first proposed for consultation in March 2020 many people questioned whether HMRC really need another disclosure rule or whether this just added another layer of ironically uncertainty to the compliance obligations of large taxpayers. The legislation as it now stands in Finance Bill 2022 is narrower in scope than the original draft legislation of July 2021 and the revised draft guidance published on 18 January offers comfort that this regime is not going to be as onerous to comply with as first appeared. In many cases taxpayers will not be required to notify under the...

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