Consultation on Extending Uncertain Tax Treatment Regime

HMRC Policy Papers & Consultations

Published March 12th, 2026

Detected March 12th, 2026

Summary

HM Revenue & Customs has launched a consultation proposing to extend the Uncertain Tax Treatment (UTT) regime. The proposal aims to capture more legal interpretation uncertainties across various taxes and apply to wealthy individuals and trusts with tax advantages over £5 million. The consultation closes on June 4, 2026.

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What changed

HM Revenue & Customs (HMRC) is seeking feedback on proposals to extend and enhance the Uncertain Tax Treatment (UTT) regime. The consultation aims to reduce tax gaps arising from legal interpretation uncertainties by requiring notification of a wider range of issues. Proposed changes include expanding the scope of UTT to 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). Additionally, wealthy individuals and trusts with tax advantages exceeding £5 million due to legal interpretation uncertainties would be brought within scope.

Regulated entities and affected parties are invited to provide feedback on the proposed widening of scope and potential new triggers for notification. The consultation period closes on June 4, 2026, and the feedback will inform the design and implementation of future legislation. While this is a consultation and therefore non-binding, failure to engage or prepare for potential future changes could lead to compliance challenges and increased scrutiny from HMRC.

What to do next

Review proposed changes to the Uncertain Tax Treatment (UTT) regime.
Submit feedback to HMRC by the consultation deadline of June 4, 2026.
Assess potential impact of expanded UTT scope on current tax treatments and reporting obligations.

Source document (simplified)

Open consultation

Consultation: Extend Notification of Uncertain Tax Treatment (UTT) regime

From: HM Revenue & Customs Published 12 March 2026 Get emails about this page

Summary

The consultation proposes extending UTT to capture more legal interpretation uncertainties and seeks views on widening scope and implementing changes.

This consultation closes at
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11:59am on 4 June 2026
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Consultation description

This consultation sets out government proposals to extend and enhance the Uncertain Tax Treatment (UTT) regime. It 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 £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. This consultation invites feedback to support the design and implementation of future legislation, and to help us understand its practical impacts.