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Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov

Most recent HMRC clearances content

Practice notes
This Practice Note is about the tax anti-avoidance rules that apply to a share for share (or share for loan note) exchange or a scheme of...
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10th May
Practice notes
This Practice Note is about the following aspects of the tax rules on statutory (ie dividend) demergers:•the anti-avoidance rules concerning...
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4th May
Practice notes
This Practice Note covers the:•clearance procedure, and•administrative rules (enquiries, counteraction notices and appeals)relating to the...
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12th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note covers the anti-avoidance measure for transactions in land...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
The EIS is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax reliefs to individual investors...
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9th Apr
Practice notes
Coronavirus (COVID-19): HMRC are unable to accept non-statutory clearance applications made by post due to COVID-19. Applications for clearance should...
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9th Apr
Practice notes
Various tax provisions include a procedure under which a taxpayer can apply for a clearance from HM Revenue & Customs (HMRC) in respect of a specific...
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24th Feb
Precedents
[Team Leader][insert HMRC address][insert date]Application for clearances in advance under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains...
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14th Feb
Precedents
[Team Leader][insert HMRC address][insert date]Application for clearance[s] in advance under section 1091 of the Corporation Tax Act 2010[ and...
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Produced in partnership with Robert Langston of Saffery Champness 12th Feb
Precedents
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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17th Dec
Precedents
Small Company Enterprise Team(Admin team) Mid-size Business S07777NewcastleNE98 1ZZ[Insert date][Commercially sensitive information]Dear [insert...
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29th Nov
Precedents
Small Companies Enterprise Centre (Admin team)Mid-size Business S0777NewcastleNE98 1ZZ[Insert date][Commercially sensitive information]Dear [insert...
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29th Nov
Precedents
HM Revenue & Customs[insert appropriate team- this is usually the HMRC Non-Statutory Clearance Team S0563][insert relevant HMRC address]by email:...
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29th Nov

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