- Draft Finance Bill 2022—notification of uncertain tax treatment
- What, in outline, does the draft legislation do, and who will be affected by it?
- How is an uncertain tax treatment defined?
- What is the consultation history behind these measures?
- Are there any substantial differences between the draft clauses and the provisions outlined in March 2021?
- What are the most difficult or contentious aspects of the new rules?
- In your view, are the new rules likely to achieve HMRC’s stated aim of reducing tax losses caused by businesses adopting uncertain tax treatments?
- When will the legislation come into effect?
Tax analysis: Kevin Elliott, director at KPMG and specialist in tax dispute resolution, discusses the new requirement for large businesses to notify HMRC of uncertain tax treatments.
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