HM Revenue & Customs (HMRC) has opened a consultation on proposals to extend and enhance the Uncertain Tax Treatment (UTT) regime, aiming to capture more legal interpretation uncertainties and reduce the tax gap. Feedback is invited until 4 June 2026.
The UK’s HM Revenue & Customs (HMRC) initiated a public consultation, on 12 March 2026, regarding the expansion and improvement of the Uncertain Tax Treatment (UTT) regime, under which large in-scope taxpayers must inform HMRC of any uncertain tax treatment.
This consultation aims to reduce the legal interpretation portion of the tax gap by requiring more legal interpretation uncertainties to be notified to HMRC.
Proposed changes include widening the scope of UTT to additional taxes — such as Stamp Duty Land Tax (SDLT), National Insurance contributions (NICs), the Construction Industry Scheme (CIS), Inheritance Tax (IHT) and Capital Gains Tax (CGT) — and bringing wealthy individuals and trusts within scope where legal interpretation uncertainties give rise to a tax advantage over GBP 5 million.
The consultation also seeks views on introducing an additional trigger to capture uncertainties not currently notifiable, improving consistency and early visibility of issues. It invites feedback to support the design and implementation of future legislation, and to help us understand its practical impacts.
Public feedback will be accepted until 4 June 2026.
