Corporation Tax

Notification of uncertain tax treatment ― administration

Produced by Tolley
  • 05 May 2022 06:51

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Notification of uncertain tax treatment ― administration
  • Introduction
  • Uncertain tax treatment ― making the notification
  • Who is responsible for making the notification?
  • Form of notification
  • Deadline for notification
  • Penalties for failure to notify an uncertain tax treatment
  • Uncertain tax treatment notification ― interaction with other regimes

Notification of uncertain tax treatment ― administration


This guidance note follows on from the Notification of uncertain tax treatment ― overview guidance note which explains the scope and operation of the regime. For those companies and partnerships that are within the remit of the rules, the requirement to notify HMRC applies where they adopt an uncertain tax treatment for corporation tax, VAT or income tax (both self assessment and amounts collected via PAYE) and the filing date for that return is on or after 1 April 2022.

A return for each of the taxes within the scope of the regime is referred to in the legislation as a ‘relevant return’. The notification obligation applies where a large company delivers a relevant return to HMRC for a financial year and the return contains an amount (including where the amount is nil) which is uncertain at the time the return is delivered or where it becomes an uncertain amount after the return is filed and is due to an accounting provision being made to reflect the probability of a different tax treatment being applied. A relevant return for these purposes includes part-year returns and amended returns. A notification is required for each relevant return that contains an uncertain amount. This means, for example, that a company that makes corporation tax, VAT and PAYE returns for a relevant period may be required to make multiple notifications.

Where a relevant return for a relevant tax includes more than one uncertain amount, only one notification

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