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Notification of uncertain tax treatment by large businesses

The proposal is designed to improve HM Revenue and Customs’ ability to identify issues where businesses have adopted a different legal interpretation to the view of HM Revenue and Customs.

This requirement will help to reduce tax losses caused by businesses adopting tax treatments that do not stand up to legal scrutiny. This proposal is not intended to suggest that HMRC’s interpretation is always correct or that a difference in legal interpretation is avoidance or evasion.

This consultation seeks views on the method and detail of the notification and particular areas of uncertain tax treatment.

The notification requirement is due to come into effect from April 2021.

Source: gov.uk

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