Large businesses are required to notify HMRC of uncertain tax treatments. The new rules include VAT returns (due to be filed from 1 April 2022) with the aim of improving HMRC’s ability to identify issues where businesses have adopted a different ‘legal interpretation’ to HMRC.
The requirement will only apply to ‘large businesses’ – ‘large business’ broadly being aligned to the current threshold tests for the Senior Accounting Officer (SAO) provisions under Finance Act 2009.
In summary, the test will be based on the £200m UK turnover and £2bn UK balance sheet test.
If you have any questions regarding the notification of uncertain tax treatments, please contact Sandy Cochrane.