Taxes Consolidation Act 1997 section 111AAQ

Expression of doubt

Section 111AAQ explains how an entity can file an expression of doubt in relation to its GloBE tax liability, and the consequences of doing so.

• An entity unsure about the correct application of GloBE tax law may submit its return based on its best understanding, accompanied by a formal "letter of expression of doubt" and supporting documentation, provided everything is filed by the specified return date.
• A valid expression of doubt is treated as a full and true disclosure; any additional tax arising from a Revenue amendment is payable within one month of the amended assessment rather than from the original due date.
• Revenue may reject an expression of doubt as not genuine if the matter is considered sufficiently clear-cut or if the entity is suspected of tax evasion or avoidance, in which case any additional tax is payable from the original due date and interest applies.
• An entity that disagrees with Revenue's rejection of its expression of doubt may appeal the decision to the Appeal Commissioners within 30 days of receiving notice of that decision.