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Welcome to the Newsletter from Walsh & Co

The Chartered Institute of Taxation (CIOT) has warned that government plans to expand the rules mandating some taxpayers to declare 'uncertain' tax positions risk generating more uncertainty. It branded the plans 'unworkable' and 'needing further development' before legislation is created.


Expansion of 'uncertain tax treatment' rules cause for concern

Government plans to extend the rules requiring some taxpayers to declare 'uncertain' tax positions risk creating more compliance burdens and tax disputes according to the Chartered Institute of Taxation (CIOT).

The uncertain tax treatment regime currently requires large businesses to flag uncertain interpretations of tax law to HMRC upfront if significant amounts of money are at stake.

The government is proposing to turn it into a much wider transparency regime, reaching beyond large businesses into individuals and trusts, expanding to cover additional taxes and potentially introducing a new, much broader trigger for notification.

The CIOT is warning that the proposed third trigger - where there is more than one 'credible' interpretation and HMRC's view is not known - is too subjective to work effectively in practice.

Lauren Fletcher, Tax Technical Senior Manager at the CIOT, said: 'These proposals would expand the uncertain tax treatment rules to more taxpayers, more taxes and a broader set of uncertainties - a potentially significant compliance expansion. But they are unworkable in their current form and need further development before any legislation is brought forward.

'The government is right to want to reduce the 'legal interpretation' tax gap and give taxpayers more certainty. But these proposals risk doing the opposite regarding certainty. A notification regime should provide clarity, not create a fresh layer of uncertainty around whether a taxpayer is required to notify in the first place.'


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ESSENTIAL TAX DATES FOR JULY

5 July
Deadline for applying for a PAYE Settlement Agreement for 2025/26.

6 July
Deadline for forms P11D and P11D(b) for 2025/26 to be submitted to HMRC and copies to be issued to employees concerned.
Deadline for employers to report share incentives for 2025/26.

14 July
Due date for Income Tax for the CT61 period to 30 June 2026.

19 July
Class 1A NICs due for 2025/26.
PAYE, Student loan and CIS deductions due for the month to 5 July 2026.
PAYE quarterly payments are due for small employers for the pay periods 6 April 2026 to 5 July 2026.

31 July
Second payment on account 2025/26 due.


QUOTE OF THE MONTH

'We're building on the success of our expert debt services to help tens of thousands more get back on their feet.'

Rachel Blake, Economic Secretary to the Treasury, commenting on an announcement from the Treasury regarding extra funding to boost debt advice services for small businesses.


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