22. Statements of practice by HM Revenue and Customs.

Although not law, statements of the practice of HM Revenue and Customs are important in the practical application of the legislation. Such statements comprise:

1.  

   (1)     published extra-statutory concessions;

2.  

   (2)     published statements of practice; and

3.  

   (3)     statements used for internal guidance including tax inspector manuals.

Extra-statutory concessions are of general application, but in a particular case there may be special circumstances which will require to be taken into account in considering the application of the concession¹. A concession will not be given in any case where an attempt has been made to use it for tax avoidance². The legality of such