Evaluation of Uncertain Tax Treatment

We are carrying out research on the notification of Uncertain Tax Treatment (UTT) requirement.

We are carrying out research on the notification of Uncertain Tax Treatment (UTT) requirement, which aims to reduce the legal interpretation portion of the tax gap. The tax gap is the difference between the amount of tax that should, in theory, be collected by HMRC against what is actually collected and legal interpretation losses arise where the customer’s and HMRC’s interpretation of the law and how it applies result in a different tax outcome. This research will help HMRC understand how large businesses view UTT, the impact of UTT on engagement with HMRC, and businesses likelihood of adopting a UTT.

About the study 

Large businesses are required to inform HMRC, at an early stage, that they have adopted an Uncertain Tax Treatment (UTT), for Corporation Tax, Income Tax (including payroll), and Value Added Tax, where the tax difference in treatment between the business’s treatment and HMRCs known position, exceeds £5 million. Or where the business has created a provision of £5 million (or more) to reflect that there is uncertainty around the correct treatment.

HM Revenue and Customs (HMRC) has commissioned the National Centre for Social Research (NatCen), an independent research organisation, to conduct research on the Uncertain Tax Treatment (UTT) requirement.

What will it involve?

Taking part will involve an interview with a NatCen researcher at a time convenient for you in March, April or May 2024. The interview will last up to 45 minutes. The interview will take place either by telephone or video call (MS teams), whichever you prefer.

During the discussion you will be asked to share your views on the following topics:

  • Your role and responsibilities, nature of your business and overview of your tax affairs 
  • Your awareness and understanding of UTT and any previous experiences of legal interpretation issues and uncertain tax treatments
  • Whether and how your engagement with HMRC or your behaviour regarding UTTs might change since the introduction of the requirements to notify HMRC of uncertain tax treatments
  • The expected resource costs for your business in complying with UTT and in seeking certainty from HMRC on uncertain tax issues more generally

Given that the interview will explore expected resource costs associated with UTT, you may want to prepare for this in advance. 

HMRC are interested in gathering a wide range of feedback, including positive and less positive views, where relevant.

Everything you say will be confidential and anonymous. Only NatCen will know you have taken part. We will not tell HMRC or anyone else what you have personally said or about compliance related to conduct.

At the start of the interview we will ask your permission to audio record the discussion so we have an accurate record of what was said. We will store your information securely and your details will not be shared with anyone else outside the research team or with HMRC. 

We may also be conducting another round of interviews at a later point to further understanding around the UTT requirement. At the end of the interview we will ask whether you also give us permission to re-contact you about this additional stage of the research. 

Reports and publications will not identify any individuals, nor businesses. 

For more information on how your data will be used, visit the privacy notice.

Taking part in an interview will not affect your relationship with HMRC in any way. 

Why take part?

Your feedback is important. Your participation will help HMRC develop a better understanding of how businesses view UTT and whether UTT is meeting its aims.

You do not have to take part if you do not want to, and you can change your mind at any time. If you do choose to take part, you do not have to answer any questions you do not want to, and you can stop the interview at any point.

As a thank you, you will receive a £75 voucher for yourself or £75 as a charity donation.

Not everyone who expresses an interest in the research may be able to take part.

Why have I been selected to take part? 

You have been invited to take part in an interview with NatCen because your business is within scope of the  UTT requirement. We want to interview representatives from large businesses, including partnerships and LLPs, who have a turnover above £200 million and/or a balance sheet total over £2bn. 

If you do not want to take part

Taking part is voluntary, and you are not obliged by your employer or HMRC to participate in this research. If you choose not to get involved, it will not affect your relationship with HMRC or any other research you may be involved in. 

Who is carrying out the research?

The National Centre for Social Research (NatCen) will be carrying out the research. The research is being carried out for the HMRC.

Contact us

If you have any further questions or would like to discuss the research, please contact us using the details below. 

Email: UTTresearch@natcen.ac.uk

Freephone: 0800 652 9295 (Monday to Friday, 9:00am to 8:00pm)

If you would like to speak to somebody at HMRC about the research you can contact HMRC’s research team at: customer.research@hmrc.gov.uk or visit www.gov.uk/guidance/check-genuine-hmrc-contact-that-uses-more-than-one-communication-method for more information.