It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).
There were some sighs of relief on L-day 2021 when the government published its draft legislation for requiring large businesses to notify uncertain tax treatments. The government had listened to two rounds of consultation and reduced the seven triggers for notification to three retaining the seemingly more objective tests. However some key points of uncertainty remained as highlighted in this journal (‘Notification of uncertain tax treatments: why it’s time to take notice’ (H Buchanan & J Tolman) Tax Journal 30 July 2021).
It was hoped that these points would be addressed in HMRC’s long-anticipated draft guidance which arrived on 19 August. Unfortunately as currently drafted the guidance offers limited...
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It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).
There were some sighs of relief on L-day 2021 when the government published its draft legislation for requiring large businesses to notify uncertain tax treatments. The government had listened to two rounds of consultation and reduced the seven triggers for notification to three retaining the seemingly more objective tests. However some key points of uncertainty remained as highlighted in this journal (‘Notification of uncertain tax treatments: why it’s time to take notice’ (H Buchanan & J Tolman) Tax Journal 30 July 2021).
It was hoped that these points would be addressed in HMRC’s long-anticipated draft guidance which arrived on 19 August. Unfortunately as currently drafted the guidance offers limited...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")