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) published extra-statutory concessions;
(2) published statements of practice; and
(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
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