- A new HMRC consultation was published on 12 March 2026 seeking views on the government’s proposal to extend the Notification of Uncertain Tax Treatment (UTT) regime.
- The proposal is to extend the scope of the regime by applying it to individuals and trusts; bringing additional taxes within the scope of the notification requirement; and introducing a new ‘trigger’ for notification where there is more than one credible legal interpretation and HMRC’s view is not known.
- Timing: the government intends that any legislation will be introduced in the next available finance bill and apply to returns filed after 1 April the following year. The consultation closes on 4 June 2026.
Resources (click to open)
- HMRC launches consultation on extending uncertain tax treatment regime (Deloitte tax@hand, March 2026)
- Opportunities to Extend Uncertain Tax Treatment (HMRC, March 2026)
