At the March 2020 Budget, the government announced that it intended to require large businesses to notify HMRC where they have adopted an uncertain tax treatment. The stated aim was to improve HMRC’s ability to identify where businesses have adopted a different legal interpretation to theirs and to address and resolve those issues earlier, and ultimately to reduce the tax gap.

Between March and August 2020, HMRC ran a consultation on the proposal, seeking views on the method and detail of the notification and particular areas of uncertain tax treatment.