In our latest tax break podcast, partner Ian Hyde is joined by Heather Self of accountants Blick Rothenberg to discuss HMRC's proposal to require large businesses to report uncertain tax positions to HMRC. This is intended to alert the tax authorities to large businesses taking an aggressive/optimistic approach to statutory interpretation.
Although large businesses often do in practice already disclose significant uncertainty upfront, HMRC is consulting on bringing in this new self reporting obligation from April 2022. This podcast covers which companies will be subject to this new requirement, what exactly is meant by "uncertain", how the threshold could apply in practice and how the transitional period may work. There is also a discussion about how the regime may operate in practice and which companies might face the biggest challenges from this change.
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