V5.220 Notification of uncertain tax treatment by large businesses
This paragraph covers the notification rules for uncertain tax treatment which apply to certain large businesses (including companies and partnerships) in relation to relevant returns that are required to be made on or after 1 April 20221.
For the penalties associated with a business not discharging its obligations under these provisions, see V5.302G.
Background to the uncertain tax treatment notification provisions
At Spring Budget 2020, the government announced that large businesses would need to notify HMRC of uncertain tax treatments. An initial consultation, 'Notification of uncertain tax treatment by large businesses' was launched in March 2020 to seek views on how the notification regime should operate.
A second consultation2 ran from 23 March to 1 June 2021 and built on the views received from the initial consultation.
The legislation ultimately appeared in FA 2022 and had been further amended from the draft legislation published in July 2021, notably dropping a a controversial notification trigger where there is a 'substantial
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