The rules are a substantial improvement on the original proposals but are still a significant a compliance burden.
HMRC’s recently published guidance states that the new uncertain tax treatment (UTT) legislation is intended to help reduce the legal interpretation portion of the tax gap – that is cases where HMRC and the taxpayer adopt differing views of the meaning of the relevant tax law – by promoting early identification and disclosure to HMRC of tax uncertainties.
The UTT legislation in FA 2022 Sch 17 has changed substantially from what was initially proposed; there are now only two notification triggers a significant reduction to the originally proposed seven. Broadly the first notification trigger applies where a provision has been recognised in the accounts to reflect that a different tax treatment may apply to a transaction (the ‘accounting provision trigger’) and the second notification trigger applies where reliance is placed...
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The rules are a substantial improvement on the original proposals but are still a significant a compliance burden.
HMRC’s recently published guidance states that the new uncertain tax treatment (UTT) legislation is intended to help reduce the legal interpretation portion of the tax gap – that is cases where HMRC and the taxpayer adopt differing views of the meaning of the relevant tax law – by promoting early identification and disclosure to HMRC of tax uncertainties.
The UTT legislation in FA 2022 Sch 17 has changed substantially from what was initially proposed; there are now only two notification triggers a significant reduction to the originally proposed seven. Broadly the first notification trigger applies where a provision has been recognised in the accounts to reflect that a different tax treatment may apply to a transaction (the ‘accounting provision trigger’) and the second notification trigger applies where reliance is placed...
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:
