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Uncertain tax treatment

13 October 2020 / Andrew Oury
Issue: 4764 / Categories: Comment & Analysis
Uncertain predictions

Key points

  • Consultation on differing legal interpretations in tax.
  • Proposed uncertain tax treatment regime would apply to large businesses.
  • The tax gap suggests that smaller businesses are responsible for much of the tax gap.
  • More of HMRC’s resources should be targeted at supporting smaller businesses rather than large ones.
  • Do HMRC’s manuals stand up to legal scrutiny?

In March HMRC launched a consultation Notification of uncertain tax treatment by large businesses with a view to addressing the £6.2bn (18%) attributed to ‘legal Interpretation’ by HMRC’s estimate of the tax gap ( In essence it seeks to require large businesses to notify HMRC when they have adopted an uncertain tax treatment. It will apply to large businesses – corporates limited liability partnerships and partnerships – which are defined as those which satisfy either or both of:

  • a turnover above £200m; or
  • a balance sheet total over £2bn....

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