The following Tax guidance note provides comprehensive and up to date legal information covering:
[insert HMRC address]
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]]
We act for [insert name of the target company] (Company A) [and on behalf of the shareholders in Company A]. We are writing to seek confirmation under:
[section 138 Taxation of Chargeable Gains Act 1992 (TCGA 1992) that section 137 TCGA 1992 will not apply;]
[section 139(5) TCGA 1992 that that subsection will not apply;]
[section 701 Income Tax Act 2007 (ITA 2007) that no counteraction notice ought to be served under section 698 ITA 2007; and]
[section 748 Corporation Tax Act 2010 (CTA 2010) that no counteraction notice ought to be served under section 746 CTA 2010;]
in respect of the proposed transactions detailed in this letter (the Transactions).
Details of Company A
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
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