Part 2 Requirement to Notify HMRC of Uncertain Tax Treatment
Finance Act 2022 (2022 c 3) | Legislation

Part 2 Requirement to Notify HMRC of Uncertain Tax Treatment

Requirement to notify

8

(1)     Sub-paragraph (2) applies if—

(a)     a relevant return is delivered to HMRC for a financial year by, or in respect of, a company or partnership, and

(b)     the company or partnership is a qualifying company, or qualifying partnership, in that financial year.

(2)     The company or partnership must notify HMRC if the relevant return includes an amount (including nil) brought into account for the purposes of a relevant tax and—

(a)     at the time the return is delivered to HMRC, the amount is an uncertain amount (see paragraph 10), or

(b)     after the return is delivered to HMRC, the amount becomes an uncertain amount by virtue of paragraph 10(2) (accounting provision made to reflect the probability that a different tax treatment will be applied to a transaction to which the amount relates).

(3)     In sub-paragraph (2)—

(a)     the reference to an amount included in a relevant return includes the inclusion of that amount as a result of an amendment of the return (other than amendment made by HMRC), and

(b)     in such a case, references to the return being delivered

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