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ESG Diligence: The Key To Sustainable M&A Transactions
AAB / Blog / Large Business Notification Requirement of Uncertain Tax Positions
BLOG6th Apr 2022
HMRC have introduced new legislation on Uncertain Tax Treatments (UTT) for large businesses. The legislation is now in force, with effect from 1 April 2022.
Certain large companies and partnerships are required to notify HMRC of uncertain tax treatments which are included in the relevant return submitted to HMRC on or after 1 April 2022. Relevant returns include corporate tax, VAT and income tax returns (including self assessment and PAYE returns) and notifications will be required where there is uncertainty surrounding the following criteria:
Large companies are generally those with a UK turnover exceeding £200m and a UK balance sheet of £2bn and includes UK companies, partnerships, limited liability partnerships, UK branches and UK permanent establishments.
There are exemptions available and a de minimis limit of £5m which reduce the compliance obligation. However, penalties will apply for late notifications, for incomplete or inaccurate notifications or for non-submission of a notification. The penalties start at £5,000 and increase up to £50,000.
If you have any queries or want to discuss how this may impact on your business, please get in touch with Helen Brown, Director of International Tax, or your usual AAB contact.
Find out more about AAB’s International Tax team.
How AAB can help you with
Corporate Tax covers a broad and complex area of tax legislation, so we provide a suitably broad and comprehensively experienced team to support your business with pragmatic, commercial advice. Businesses of all sizes and types, and across a wide range of sectors, benefit from our comprehensive corporate tax compliance and advisory service. We have exceptionally knowledgeable tax teams distributed across our offices, ready to support you with their wealth of experience and expertise. We can manage your global tax exposure with a coordinated response that saves you having to seek advice from separate advisors.
If you’re facing multi-jurisdictional challenges around global mobility, tax, employer responsibilities, accounting or other issues, we’ll save you the hassle of searching for international advice – the right people are already available in our expert teams and across our Reach Network. AAB works with multinational clients across the globe, so it’s only logical that we have a comprehensive and highly effective support network that work alongside our International teams to serve them, wherever in the world they operate.
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