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Introduction

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