The UK government on August 19 published guidance relating to the upcoming uncertain tax treatment notification requirement for large businesses.
The guidance follows the July 20 release of draft legislation for Finance Bill 2021-22, which includes provisions adopting the uncertain tax treatment notification requirement. Under the new requirement, large businesses will have to notify the UK tax agency if they adopt an uncertain tax treatment with respect to returns filed on or after April 1, 2022.
The uncertain tax treatment notification requirement would apply to both large corporations and partnerships that meet the threshold criteria. For purposes of determining in-scope businesses, the guidance clarifies certain issues relating to the relevant turnover and balance sheet amounts, defines “group,” and addresses application to certain specific kinds of entities.
In addition to the clarifications regarding in-scope entities, the guidance covers the notification criteria that trigger the reporting requirement, the threshold test under which transactions become reportable, the notification process, exemptions, and penalty assessments.
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