The United Kingdom’s (UK) Finance Bill 2021-22, published on 4 November 2021, includes proposed legislation for the new notification of uncertain tax treatment (UTT) regime.
The UTT regime will require large businesses to notify Her Majesty’s Revenue & Customs (HMRC) of “uncertain amounts” in respect of corporation tax, value-added tax (VAT) or income tax (including PAYE – Pay As You Earn), subject to a threshold test and specific exemptions. A treatment is defined as being “uncertain” if it falls within one (or more) of the two specified conditions (or “triggers”).
The proposed legislation included in Finance Bill 2021-22 makes a significant change to the definition of uncertain amount’ as compared to the draft legislation published earlier this year. One of the proposed triggers – which would have been satisfied whenever there was a “substantial possibility” that a court or tribunal would find the treatment to be incorrect – has now been removed.
Source EY
