UK Tax Authority Seeks Input on Expanded Tax Uncertainty Regime

March 12, 2026, 2:36 PM UTC

The UK’s tax authority detailed its expanded tax uncertainty alert regime, aimed at narrowing the country’s sizable tax gap, in a new consultation announced Thursday.

His Majesty’s Revenue & Customs proposed including the Stamp Duty Land Tax, National Insurance contributions, the Construction Industry Scheme, Inheritance Tax, and Capital Gains Tax in the expanded Notification of Uncertain Tax Treatment regime.

The UTT was introduced in 2022 to alert HMRC to uncertain legal interpretations of tax treatment and allow for a quicker resolution. The policy requires large businesses to notify the tax authority if they take a tax position that ...

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