FORTHCOMING CHANGE: At Tax Update 2026, HMRC published a consultation on ‘Modernising the distributions framework’. As part of the package of announcements designed to limit opportunities for taxpayers to extract value from companies as capital rather than income, HMRC proposed the replacement of the existing transactions in securities regime with an updated anti-avoidance regime that is ‘expected to be clearer and more principles based’. HMRC is concerned the current rules ‘reflect an outdated approach to anti-avoidance legislation and can be difficult to apply, which makes them less effective than intended in relation to certain structures.’ [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 Introduction 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)

HM Revenue & Customs [insert appropriate HMRC team] [insert relevant HMRC address] by email: nonstatutoryclearanceteam.hmrc@hmrc.gov.uk [ Commercially sensitive information ] Dear [insert organisation name] Clearance service: non-statutory clearance application—[insert type of tax legislation which is the subject of the clearance application] and its application to [a] transaction[s] involving [name of company] (the Company) 1 Information about the applicant and our authority to act as agent We act for [insert name of the company] (the Company) incorporated in [insert place of incorporation] on [insert date of incorporation] with company registration number [insert company number] and its registered office is at [insert address]. The Company’s [corporation tax reference OR PAYE reference OR VAT registration] number is [insert the number]. We are authorised by the Company to seek the view of HM Revenue & Customs (HMRC) on [insert brief description

FORTHCOMING CHANGE relating to chargeable payments and advance clearances: At Tax Update 2026, HMRC published a consultation on ‘Modernising the distributions framework’. The consultation includes a range of proposals aimed at reducing opportunities for income tax payers to extract value from companies in the form of capital rather than income. In relation to statutory (direct and indirect) demergers, Chapter 3 of the consultation proposes relaxing the tax conditions in CTA 2010, Pt 23, Chapter 5. However, the consultation also proposes removing the automatic right of appeal to the Tribunal where a clearance request under CTA 2010, ss 1091 and 1092 is denied. For more information on the consultation, see News Analysis: Tax update 2026—Tax analysis—Companies and corporation tax. [Team Leader] [insert HMRC address] [insert date] Application for clearance[s] in advance under section 1091 of the Corporation Tax Act 2010[ and sections 138 and 139(5) of the Taxation of Chargeable Gains Act 1992] 1 Introduction We act for [insert name of the target company] (Company A) [and on behalf of the shareholders in Company A]. Company A is the ‘distributing

Procedure whereby companies and individuals can seek advanced clearance from the Pensions Regulator that proposed transactions will not fall foul of the anti-avoidance provisions set out in the Pensions Act 2004.

What is clearing of derivatives? Clearing is a process which eliminates the normal risk that a party to a derivatives transaction will default. The main parties involved in the clearing process are: • a financial institution known as a clearing house or central counterparty (CCP), and • other financial institutions, usually banks or brokers, which enter into a clearing agreement with the clearing house—these institutions are known as clearing members of the clearing house or simply clearing firms In cleared transactions: • all transactions are entered into by clearing members, which may do this for their own accounts or for the accounts of their clients, and • the clearing house interposes itself between the clearing members who have entered into the transaction, becoming a party to every transaction—each party, therefore, is exposed to the risk of the clearing house but not to the risk of the other party The way in which the clearing house is interposed between the clearing members depends on whether the clearing house uses: • the

Introduction This Practice Note is 1 of 2 that provide an overview of processes, law and regulation governing the clearing and settlement of securities in the UK. This Practice Note focuses on the clearing element of the process. For more information about the settlement element of the process, see Practice Note: Clearing and settlement of securities—settlement. Background to clearing and settlement ‘Clearing and settlement’ is the terminology commonly used to describe the process, following the agreement of a trade in a financial instrument, by which the obligations of each party to the trade are first confirmed, and then performed. A transaction in securities will typically have the following stages: • confirmation of the trade • clearing, and • settlement The first two stages are described in more detail below. The third stage is described in Practice Note: Clearing and settlement of securities—settlement. Confirmation of the trade Before the clearing and settlement of a trade can commence, there must first be a confirmation of the agreement of the buyer to purchase a specified

Introduction This Practice Note is one of two which provide an overview of processes, law and regulation governing the clearing and settlement of securities in the UK. This Practice Note focuses on the settlement element of the process. For more information about the clearing element of the process, see Practice Note: Clearing and settlement of securities—clearing. Background to clearing and settlement ‘Clearing and settlement’ is the terminology commonly used to describe the process, following the agreement of a trade in a financial instrument, by which the obligations of each party to the trade are first confirmed, and then performed. A transaction in securities will typically have the following stages: • confirmation of the trade • clearing, and • settlement The first two stages are described in Practice Note: Clearing and settlement of securities—clearing. The third stage is described more detail below. Settlement Settlement is the process by which the respective obligations of the buyer and seller are discharged. Settlement involves the delivery of the relevant quantity of securities

A system through which securities' sales are settled and cleared such as Euroclear and Clearstream

Corporate Crime analysis: The Tobacco and Vapes Bill received Royal Assent on 29 April 2026 and represents one of the most significant moves in public health regulation to be legislated for generations. The most important effect of the legislation will be that anyone born on or after 01 January 2009 will never be able to legally purchase tobacco products in the UK. The Secretary of State for Health and Social Care, Rt. Hon. Wes Streeting MP, described the legislation as: “..a turning point for the nation’s health… ending the cycle of tobacco addiction for future generations… [and] one of the boldest steps in decades to prevent illness before it even begins.” Mark Watson at Mountford Chambers examines the Act’s phased implementation and its implications for retailers, manufacturers, distributors and enforcement authorities, with particular focus on the creation of new offences, the role of ‘reasonable steps’ defences, and the compliance burden this places on businesses.

One of the clearing systems used for European debt securities offerings.

Clearstream and Euroclear Bank, the two International Central Securities Depositories, have announced the launch of their respective dematerialised Eurobond issuance services, which are now live and available for market use. The services remove the need for physical global certificates, enabling Eurobonds to be issued in fully paperless form through both depositories. The initiative is intended to enable faster processing, improve operational efficiency and reduce costs. The dematerialised frameworks also enhance security by eliminating risks associated with loss, theft or forgery, and provide greater transparency through electronic ownership records. Dematerialised Eurobonds can initially be issued under English law, with further jurisdictions expected to be added.

Clearstream, the Depository Trust & Clearing Corporation (DTCC) and Euroclear have published a joint white paper, together with Boston Consulting Group, proposing an interoperability framework for digital asset securities. The paper sets out a structured taxonomy designed to align distributed ledger technology networks with traditional financial market infrastructures.