Clearance letter—TCGA 1992, ss 138 and 139(5), ITA 2007, s 701 and CTA 2010, s 748
Clearance letter—TCGA 1992, ss 138 and 139(5), ITA 2007, s 701 and CTA 2010, s 748

The following Tax precedent provides comprehensive and up to date legal information covering:

  • Clearance letter—TCGA 1992, ss 138 and 139(5), ITA 2007, s 701 and CTA 2010, s 748
  • 1 Introduction
  • 2 Details of Company A
  • 3 Details of Company B and the other parties involved in the Transactions
  • 4 The Transactions
  • 5 Commercial rationale for the Transactions
  • 6 Clearances sought
  • 7 Contact details
  • Schedule 1
  • Schedule 2
  • More...

Clearance letter—TCGA 1992, ss 138 and 139(5), ITA 2007, s 701 and CTA 2010, s 748

[Team Leader]

[insert HMRC address]

[insert date]

Application for clearances in advance under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains Act 1992][ and ][section 701 Income Tax Act 2007[ and section 748 Corporation Tax Act 2010]]

    1. 1

      Introduction

      1. 1.1

        We act for [insert name of the target company] (Company A) [and on behalf of the shareholders in Company A]. We are writing in respect of the proposed transactions detailed in this letter (the Transactions) to seek confirmation under:

        1. 1.1.1

          [section 138 Taxation of Chargeable Gains Act 1992 (TCGA 1992) that section 137 TCGA 1992 will not apply;]

        1. 1.1.2

          [section 139(5) TCGA 1992 that that subsection will not apply;]

        1. 1.1.3

          [section 701 Income Tax Act 2007 (ITA 2007) that no counteraction notice ought to be served under section 698 ITA 2007; and]

        1. 1.1.4

          [section 748 Corporation Tax Act 2010 (CTA 2010) that no counteraction notice ought to be served under section 746 CTA 2010.]

    1. 2

      Details of Company A

      1. 2.1

        Company A is a company incorporated in [England and Wales OR [insert name of foreign jurisdiction]] (registered number [insert registered number]) on [insert date of incorporation] and whose registered office is at [insert address].

      1. 2.2

        [Insert details of Company A's principal business

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