UK Finance has submitted a response to HMRC's ?Notification of Uncertain Tax Treatment by Large Businesses - Second Consultation?. While we note that this second consultation represents a considerable improvement on the original proposals, we flag that there remain some very significant areas of concern. In particular. we believe that applying the current scope and triggers as drafted to VAT and Transfer Pricing will be counter-productive and we have therefore outlined some alternative approaches to consider. Until these points are addressed, the reporting regime will be neither proportionate or practical and will only result in an onerous administrative and cost burden on taxpayers doing business in the UK.